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Practical Guidance on Verification of other areas in
Concurrent Audit - 13 August, 2022
C.A. Parag Hangekar
E-mail: phangekar@gmail.com
Cell: 9820577913
Income Verification
• Interest Income – CC, OD, DL, TL, Bills Purchased & Discounted,
overdue and penal interest, interest subsidy/ subvention etc.
• Commission & Fees:
– Bills for collection
– Remittances & transfers
– LCs & BGs
– Processing fees
– Lead Bank fees
– Mobile banking fees – SMS charges on quarterly basis
– Credit/ Debit card annual fees
– Locker Rent
– Govt business
– CERSAI, CIBIL, Insurance, Penal charges
C.A. Parag Hangekar 2
Interest Verification
• On test check basis interest debited by CBS
should be checked manually through product
rate sheets.
• Checking the interest run reports
• Booking of interest on credit card portfolio.
• Booking of interest on Pool Accounts – Reversal
of interest on compounded basis instead of
simple interest basis.
• Checking the movement in the interest rate
changes in the master.
C.A. Parag Hangekar 3
Income Leakages
• Checking of Borrower’s Master in the CBS with
the Sanction terms & conditions.
– Sanctioned rate of interest varies from the ROI entered in CBS.
– Borrowers sanctioned interest at 6 months, 3 months and 1
month MCLR/ RLLR. System does not update the interest rate
automatically in such cases, whenever the MCLR/RLLR is
changed by the Bank. Branch needs to manually monitor and
update interest rates in CBS.
– In case of CC facilities, MCLR/RLLR rate is required to be reset
on annual basis, however it got changed within a short period of
2-3 months. Change in Interest rate was occurring whenever
there was any alteration done in the master of client (e.g. loan
master was changed due to interchangeability of Fund based &
Non - fund based limits. CBS was taking up fresh MCLR/RLLR
as on date of master alteration.)
C.A. Parag Hangekar 4
Income Leakages
– Restructured cases:
• High number of cases under COVID/ MSME circulars
• Renegotiated interest, repayment schedule not properly
updated in CBS.
• Wrong interest being charged.
• Carving out of FITL
• Moratorium in the principal and interest but usually the
borrower is supposed to pay the interest on FITL – many
branches skip this point & account turns NPA
– Charging of penal interest on delayed submission of
stock statements, Quarterly information statements,
overdrawing of limits, ad hoc limits etc.
– Rate changed in between the months and again
amended as per sanction at the end of the month.
C.A. Parag Hangekar 5
Bills Purchased and discounted
• Check the interest booking based on the tenure
of the bills
• Check the accounting policy of the bank
• Reversal of interest in case of unexpired period
– Rebate on Bills Discounted – interest booked
upfront and then apportioned over the tenure of
the bills.
• Accrual of interest in case of overdue period –
bills not crystallized on the due dates – interest
to be booked for the overdue period.
C.A. Parag Hangekar 6
Bills Purchased and discounted
• Bill Purchased on 1.2.22 for 90 days
i.e. maturity date is 1.5.22. Income to be
accounted till 31.3.22 and remaining to be
reversed to Rebate On Bills Discounted.
• Bill Purchased on 1.12.21 for 90 days
i.e. maturity date is 28.2.22. Income to be
accrued on the overdue period for the
month of March 22.
C.A. Parag Hangekar 7
LCs/ BGs Commission
• Confirm the accounting policy of the bank
• Ascertain the period of the LCs/ BGs
• Verify the interest rate from the sanction and the
rates as per the circular
• For BGs confirm the booking of the commission
income upfront/ spread over the tenure of the BG as
per the policy
• Check the reversal of the expired BGs
• Income booked on LCs based on their tenure
• Confirm that the devolved LCs are debited to the CC
account of the borrower
C.A. Parag Hangekar 8
LCs/ BGs Commission
• Check the controls over the issue of the LCs and
BGs from the relevant module of the CBS
• Instances of issuing BGs by staff from excel –
fraudulent transactions
• Confirm the sequencing and the authentication of
the documents
• Verify the supporting for the LCs and the BGs
issued to confirm the genuineness.
• Ascertain the margins on the BGs as per the Bank
circular and the sanction letters.
C.A. Parag Hangekar 9
Suspense & Sundry accounts
• Temporary parking accounts
• Usually deposits to landlords, advances to staff
such as festival, traveling etc. shown under
Suspense. Frauds, cash shortage etc.
• To check there are no old and non-moving
entries under these heads. Appropriate provision
has been done for such items.
• Fraud/ manipulation prone area so auditor
needs to be cautious and constant monitoring of
these accounts is required.
C.A. Parag Hangekar 10
Suspense & Sundry accounts
• Ensure that multiplicity of accounts and
unnecessary accounts are not opened as
suspense accounts
• Verify the process of expeditious clearance of
items debited to suspense account and whether
the same are actually cleared
• Verify whether any office account is used for
allowing debits to accommodate temporary
overdrafts without appropriate disclosures
• Since fraud prone hence constant checking is
essential.
C.A. Parag Hangekar 11
Staff accounts
• Auditor to keep check over the high value
transactions in the staff accounts
• Debit and credit turnover can be checked in the
accounts to confirm that the same is in
alignment with the income of the staff member
• Fraud/ manipulation prone area
• RBI has observed several frauds through these
accounts.
• Constant monitoring is required
C.A. Parag Hangekar 12
Inoperative accounts
• Review of inoperative/ dormant accounts
• Sudden operations to be checked properly with due
authorizations
• Maker Checker to be verified
• Again, a fraud prone area since without proper controls
the amounts in these accounts can be siphoned away –
also can be used for manipulations – NPA window
dressing.
• Charges to be verified for non-operation of the accounts.
• As per RBI Guidelines, no penal charges are to be levied
for non-maintenance of minimum balances in any
inoperative account
C.A. Parag Hangekar 13
Transfer to DEAF
• The RBI vide its circular no. DBOD.No.DEAF
Cell. BC.101/30.01.002/2013-14 dated March
21, 2014 issued “The Depositor Education and
Awareness Fund Scheme, 2014 under Section
26A of Banking Regulation Act, 1949”
• Credit balances lying older than 10 years to be
transferred to DEAF by the Bank
• Check the ageing of the credit balances lying in
different accounts and confirm the transfer
• CBS sometimes fails to identify savings
accounts/ FDRs which were linked to LAD
C.A. Parag Hangekar 14
Transfer to DEAF
(a) savings bank deposit accounts;
(b) fixed or term deposit accounts;
(c) cumulative/recurring deposit accounts;
(d) current deposit accounts;
(e) other deposit accounts in any form or with any name;
(f) cash credit accounts;
(g) loan accounts after due appropriation by the banks;
(h) margin money against issue of Letter of Credit/Guarantee etc., or any security deposit;
(i) outstanding telegraphic transfers, mail transfers, demand drafts, pay orders, bankers
cheques, sundry deposit accounts, vostro accounts, inter-bank clearing adjustments,
unadjusted National Electronic Funds Transfer (NEFT) credit balances and other such
transitory accounts, unreconciled credit balances on account of Automated Teller Machine
(ATM) transactions, etc.;
(j) undrawn balance amounts remaining in any prepaid card issued by banks but not
amounts outstanding against travellers cheques or other similar instruments, which have no
maturity period;
(k) rupee proceeds of foreign currency deposits held by banks after conversion of foreign
currency to rupees in accordance with extant foreign exchange regulations; and
(l) such other amounts as may be specified by the Reserve Bank from time to time.
C.A. Parag Hangekar 15
Interest booking on Overdue TD
• RBI circular no. DBOD No. Leg.BC.34/
09.07.005/2008-09 dated August 22, 2008
• Savings interest rate to be booked for overdue
Term Deposits
• Check the ageing of such deposits from the CBS
• Check the working of the interest being booked
on these deposits
• Interest on overdue deposits – example of old
scheme deposits – out of CBS and done
manually in excel – check the accuracy of
calculations
C.A. Parag Hangekar 16
KYC and AML
• Compliance of KYC norms at the time of opening of
CASA or Term deposit accounts
• Application of rate of interest as per the interest table to
every product of deposits by taking sample accounts of
each type of deposit product including instances of
premature withdrawal of deposits and retrospective
renewal of deposits
• TDS flag is correctly configured wherever Form 15G/15H
has been received by the Bank and that TDS as per the
rates in force has been deducted on interest payments
C.A. Parag Hangekar 17
194A Interest from a
Banking Company/
Post Office (Other
than on Securities)
Rs. 40,000 per annum for Others /Rs.
50,000 per annum for Senior citizen
10%
KYC and AML
• Application of various charges on CASA, e.g.
Minimum Balance charges etc., on test check
basis and compliance thereof
• The accounting effects of interest payable in the
form of interest accrued but not due and interest
accrued and due are correctly given as also TDS
compliances thereon
• Compliance with internal circulars of the bank in
terms of categorisation of customers, and
application of the said terms in the master data
of such deposit holders
C.A. Parag Hangekar 18
KYC and AML
• The complaints lodged w.r.t. the customer
services and contingent liability / liability arising
thereon
• Major movements in interest expenses vs.
movements in interest bearing deposit
Data Integrity & Modifications
• Authorisation & control processes to ensure that
the customer accounts opened in the system are
properly updated in the relevant module in CBS.
• Verify the correctness KYC data updated in CBS
C.A. Parag Hangekar 19
Exception reports checking
• Obtain the list of exception reports prescribed by
bank along with its periodicity for review
• Whether the branch has followed the instructions
issued by bank w.r.t. generation and verification
of exception reports
• Review of such transactions on sample basis will
help in ascertaining the nature of the
transactions and risk involved
• Any issues which have not been complied /
marked as pending compliance, status of the
same should be obtained and reported.
C.A. Parag Hangekar 20
Exception reports checking
• Obtain instructions issued by the bank for
process to be followed when system generated
data is manually altered.
• Enquire about availability of audit trail / logs
related to such manual interventions and review
the same.
• Data integrity: verify that the data being entered
is done properly and there is proper maker
checker principle for verification of the same
• Instances of transactions reflected in Exception
Reports:
C.A. Parag Hangekar 21
Exception reports checking
• Ad hoc loans granted to borrowers
• Overdrawing allowed over the limits
• Changes in the interest rates not in line with the
products defined in CBS
• Major operations/ transactions in the newly
opened accounts
• Standalone Non Fund Based Limits granted to
customers
• Backdated updation of stock and book debt
statements
C.A. Parag Hangekar 22
Exception reports checking
• List of accounts wherein the facility is not
renewed / reviewed
• List of accounts slipped to NPA during the
current period
• List of accounts wherein there is an amendment
in date of NPA
• Loans below the benchmark rate
• Loans above the maximum lending rate
• List of accounts wherein re-phasement i.e.
Change in EMI, Tenor, Moratorium period.
C.A. Parag Hangekar 23
Exception reports checking
• CC Accounts with primary security as “Nil”
• Manual debit/credits to Interest Income and
Other Income Account
• Manual debit to Interest Expense Account
• FDs / RDs with aggregate balance at customer
master level in excess of Rs. 20,000 and closed
one / all FDs / RDs in cash
• Cash Payments from Office Accounts in excess
of Rs. 10,000
• List of Outstanding Office Accounts entries
C.A. Parag Hangekar 24
Exception reports checking
• Bank Guarantees and LC Expired and not
reversed
• Resident Customers having Non Resident
Account (under same or multiple customer
master)
• Status of the inoperative accounts
• Unit Inspections pending for long
• Manual debits to Inter office accounts
• Login in CBS by personal on leave
C.A. Parag Hangekar 25
Inter office accounts – Fraud prone
• Mostly used for internal business transactions of
banks or transactions to facilitate movement of
funds in a flow of transaction.
• Reconciliation of transactions on a daily basis
• Keep a track on un-reconciled transactions
• Major transactions which occur through inter-
office accounts:
• Payment to / receipts from other branches of the
proceeds of instruments received/sent for
collection /realization/clearing
C.A. Parag Hangekar 26
Inter office accounts – Fraud prone
• Cash sent to/received from other branches
• Payment of instruments like gift cheques/
banker’s cheques/ interest warrants/ dividend
warrants/repurchase warrants/refund warrants
• Government receipts and payments handled by
the banks
• Operations by the authorized branches on the
bank’s NOSTRO accounts through the Treasury/
International Banking Division
• Transactions through NEFT, RTGS, NACH, UPI
C.A. Parag Hangekar 27
Inter office accounts – Fraud prone
• Internet based transactions
• Credit card related transactions of the customers
• ATM transactions of the customer
• GST transactions of bank branches within a
zone and Zonal or Head office
• TDS of the branches deposited by the central
office
• Parking of subsidies received from Government
under various schemes
C.A. Parag Hangekar 28
Inter office accounts – Fraud prone
• Verify the balance in this head and should seek
explanation why the balance is not reconciled, if
any
• Unauthorized/ Objectionable practices in the
Inter Office Accounts leads to Fraud. Illustrative
instances of such practices are as follows:
Ø Deficiencies in linking the office accounts to the
Trial Balance and General Ledger
Ø Disguising cash transaction of customer to avoid
AML reporting
Ø Disbursal of loan or repayment of loan resulting
C.A. Parag Hangekar 29
Inter office accounts – Fraud prone
in misuse of funds and window dressing
• Lack of automation for identifying and reporting
of the outstanding entries
• Opening of saving and current account and
funds movement thereon misused through office
accounts
• Crediting a dummy entry by debiting the office
account to the credit of borrowers account and
then debiting so as to prevent from becoming
NPA
• Many income accounts do not have debit freeze
C.A. Parag Hangekar 30
Inter office accounts – Fraud prone
• Review the system of operation for sensitive
office accounts
• Check all material transactions outstanding in
office accounts even if it is outstanding for more
than 6 months
• Verify whether the transactions in accounts are
matching with the purpose of account for which it
is created
• Reversal entries are made under proper
authority & after due explanation and evidence
C.A. Parag Hangekar 31
Early Warning Signals (EWS)- as
per RBI
• EWS are those which should alert the bank
officials about some wrongdoings in the loan
accounts which may turn out to be fraudulent
• An illustrative list of some EWS as per RBI
Directives:
• Default in undisputed payment to the statutory
bodies as declared in the Annual Report
• Bouncing of high value cheques
• Frequent change in the scope of the project to
be undertaken by the borrower
C.A. Parag Hangekar 32
Early Warning Signals (EWS)- as
per RBI
• Delay observed in payment of outstanding dues
• Frequent invocation of BGs and devolvement of
LCs
• Invoices devoid of GSTN and other details
• Dispute on title of collateral securities
• Funds coming from other banks to liquidate the
outstanding loan amount unless in normal
course
• Funding of the interest by sanctioning additional
facilities
C.A. Parag Hangekar 33
Early Warning Signals (EWS)- as
per RBI
• Critical issues highlighted in the stock audit
report
• Exclusive collateral charged to a number of
lenders without NOC of existing charge holders
• Liabilities appearing in ROC search report, not
reported by the borrower in its annual report
• Frequent request for general purpose loans
• Frequent ad hoc sanctions
• High value RTGS payment to unrelated parties
• Heavy cash withdrawal in loan accounts
C.A. Parag Hangekar 34
Early Warning Signals (EWS)- as
per RBI
• Not routing of sales proceeds through
consortium/ member bank/ lenders to the
company
• Significant movements in inventory &
receivables, disproportionately differing vis-à-vis
change in the turnover
• Non production of original bills for verification
upon request
• Significant increase in working capital borrowing
as percentage of turnover
C.A. Parag Hangekar 35
Early Warning Signals (EWS)- as
per RBI
• Increase in fixed assets, without corresponding
increase in long term sources (when project is
implemented)
• Frequent change in accounting period and/or
accounting policies
• Claims not acknowledged as debt
• Material discrepancies in the annual report
• Substantial related party transactions
• Substantial increase in unbilled revenue year
after year
C.A. Parag Hangekar 36
Early Warning Signals (EWS)- as
per RBI
• Large number of transactions with inter-
connected companies and large outstanding
from such companies
• Resignation of the key personnel and frequent
changes in the management
• Significant reduction in the stake of promoter
/director or increase in the encumbered shares
of promoter/director
• Raid by Income tax /sales tax/ central excise
duty officials
C.A. Parag Hangekar 37
Cash Verification
• Physical verification on surprise basis of cash at
branch and ATM along with safekeeping and
custody.
• Ensure that there is no accumulation of large
stocks of heavy cash and cut/mutilated/soiled
notes, which otherwise need to be reported.
• If cash holdings are beyond the prescribed cash
retention limit, the same also need to be
reported.
C.A. Parag Hangekar 38
Cash Verification
• The concurrent auditor would also need to verify
whether cash is promptly remitted to the
currency chest or to RBI and need be reported if
the same is not being so deposited.
• Short or excess cash, that needs to be reported
• Daily cash transactions, particularly any
abnormal receipts and payments.
• Surprise verification of cash by an officer other
than the joint custodian.
C.A. Parag Hangekar 39
Cash Verification
• Proper accounting of and availability of
insurance cover for inward and outward cash
remittances.
• Accounting of currency chest transactions and
delays/omission in reporting to RBI.
• Reporting of Counterfeit Currency.
• All cash transactions of Rs. 10 lakh and above
reported in CTR (cash transaction report).
• That all cash transaction of Rs. 50,000 and
above invariably indicate Pan No./Form 60.
C.A. Parag Hangekar 40
Cash Verification
• RBI has issued Master Circular on the Scheme
of Penalties for bank branches including
currency chests based on performance in order
to ensure that all bank branches provide better
customer service to members of public with
regard to exchange of notes and coins, in
keeping with the objectives of Clean Note Policy.
C.A. Parag Hangekar 41
Manual reversal of income
• Obtain Trial Balance and Profit & Loss of the
branch for month end
• Check any negative balances appeared in
above – now a days separate ledgers for control
purpose.
• Verify the income heads & understand nature
and processing of transactions
• If manual intervention observed - verify
computation, sanction/approval from the
Controlling Authority for such reversal
• Instances of manual reversal of income:
C.A. Parag Hangekar 42
Manual reversal of income
• SCA or SBA suggested- classification of
advances leads to manual reversal non-served
interest & charges
• Excess charging of processing fee,
documentation fee, inspection charges,
commission fees, etc. to the borrower account
• Renewal charges and other incidental charges
debited even though advances not renewed.
• Several times the necessary approval is awaited
from the Zone/ Head Office.
C.A. Parag Hangekar 43
Locker Rent
• Check the accounting policy of the bank
• Check whether rent automatically credited in CBS or manually
done
• If manually computed, should check thoroughly so as to avoid
income leakages
• Verify whether locker rent properly accounted in books as per
bank’s service charges policy
• Check amount of rent arrears, periodicity and same should be
reported
• Obtain the report from CBS of the lockers sanctioned and the
income booked – usually in the first quarter of the F.Y.
amount is recovered from savings/current account.
• Check whether done centrally or at branch level.
C.A. Parag Hangekar 44
Housekeeping
• Sharing of passwords – controls
• Storage of servers, switches, routers – access to
them restricted?
• Preservation of branch records/daily vouchers
• Scrutiny of day to day vouchers
• Reporting of fraud prone areas
• Report on customer service
• Irregularities of earlier audit not rectified
• Banks accounts – Bank account reconciliation
• Government Business- Pension payments, PPF,
Collection of tax, other Govt. business, etc
C.A. Parag Hangekar 45
Housekeeping
• Follow up laid down procedure w.r.t. security
forms such as Drafts, Pay Order, FDR, etc.
• Recovery of TDS on applicable TD, payment to
contractors/landlords
• Holding customer service meeting at periodical
interval for requesting customers of all
categories (Deposit, Advances, Forex)
• Security at the Branch – Gun license
• Ghosh Jilani Report – detailed questionnaire
C.A. Parag Hangekar 46
Main expenses to be verified
• Plan the audit procedures based on control
testing for accounting and recording of items of
expenses correctly
• Check accounting policy as well
• Verify maker checker existence
• Verify whether sanction/authorization for
expenses done as per delegated powers
• Confirm that the expenses incurred pertain to
the official business of the branch
• Rent, Telephone, Electricity, Travelling, Printing
& Stationary etc.
C.A. Parag Hangekar 47
Forex & Remittances
• Verify genuineness of foreign inward
remittances, end use and purpose thereof
• From the view point of Money Laundering
• Foreign outward remittances particularly for
import transactions to ascertain the genuineness
by verifying the import bill of entry evidencing
import of goods
• Check the related booking of income – charges
and the commission for the conversion.
• Confirm that rate is proper as given by Treasury
C.A. Parag Hangekar 48
Forex & Remittances
• Verification of SWIFT messages covering inward
remittances whether such messages are authenticated
properly and received from the Bank’s authorized
overseas correspondence banks
• Outward SWIFT messages: Verify whether outward
messages are sent to the correspondent bank with
authentication
• SWIFT messages so received/sent are properly
authenticated and their stamp authenticated & Signed by
authorized officials.
• Daily reconciliation between the Swift system and the
data entered in CBS (PNB Fraud).
C.A. Parag Hangekar 49
Timely receipt of stock statements
• As per sanction terms of advances check stock
statements properly updated in CBS
• Ensure that stock statements are received on or
before the given due date.
• Verify the date stamp on the stock statements
and cross verify the date entered in CBS.
• In the event of non receipt of stock statements,
penal interest should be recovered from the due
date till the date of actual receipt and report the
same.
C.A. Parag Hangekar 50
General Points
• Reconciliation of the Government Business
accounts
• Multiple CIFs – credit card accounts.
• Closure of Deposits to be credited to loan
accounts ONLY
• Compliances on the observations – persistent
irregularities
• Debit balances in savings accounts – ATM
withdrawals and UPI payments permitted
• ECS charges debited in accounts even when
there is no balance
C.A. Parag Hangekar 51
Fixed Assets, Current Assets &
Current Liabilities
• Fixed Assets – coding and updation of the FAR
• Ensure that figures as per the trial balance from
CBS matches with the schedule of Fixed Assets
figures If different software maintained.
• Check depreciation on fixed assets calculated as
per bank’s defined policy & ensure proper
accounting in CBS.
• Verify date of recording the fixed asset in the
books of accounts and commencement of
depreciation which should be from the date, the
asset available for use in line with AS-10
C.A. Parag Hangekar 52
Fixed Assets, Current Assets &
Current Liabilities
• Ensure that assets are properly insured with
bank clause inserted in the policy proper
valuation thereof supported by original invoices
• Ensure delegation of power in purchase and
sales of fixed assets
• Examine the evidence of physical existence of
fixed assets
• Current Assets & Liabilities:
• It includes advances made to Staff, Tax paid in
advance/tax deducted at source, Sundry
C.A. Parag Hangekar 53
Fixed Assets, Current Assets &
Current Liabilities
• Debtors with bifurcation thereof, Inter-office
adjustments (net), Stationery and stamps
• Check periodicity of outstanding sundry
debtors/creditors
• Physical verification of stationery & stamps, age
wise breakup of pending entries inter-office
adjustment account with reason thereof.
• Check provision entries parked in other
liabilities.
C.A. Parag Hangekar 54
Security Valuation and updation in the System
– apportionment among various limits
• Check value of securities
pledged/hypothecated/mortgaged to the bank properly
updated in CBS
• Verify value properly apportioned among all facilities
availed by single borrower
• Verify whether there is no double entry of same
securities value which results into overstatement of
valuation against advances
• Confirm the security valuation properly in case of NPA
accounts
• Check that latest value is updated
• Verify if primary security value exists in D1/D2/ Loss
accounts
C.A. Parag Hangekar 55
Security Valuation and updation in the System
– apportionment among various limits
• In case of vehicle whether the depreciated value is being
considered.
• Collaterals are stated as per valuation report which is not
older than 3 years.
• In case of consortium accounts only the portion of
securities pertaining to the Branch have been updated in
the security value fields.
• Verify the statutory audit and stock audit reports to check
for any qualifications pertaining to stock and assets and
mention the appropriate revisions in your audit report to
the Branch.
C.A. Parag Hangekar 56
Funding of FITL accounts
• Manual transfer by the branches
• During cut off period – treatment
• Provisioning not done
• FITL opened in different code
• Check the sanction and confirm that the master
has been properly updated with the terms and
conditions of ROI and the repayment schedule.
• Ensure that interest is serviced as and when due
by the borrower.
C.A. Parag Hangekar 57
Wealth Management & Third Party
Products
Wealth Management
• Check client service agreement with wealth
management clients
• Check that the terms of such service
agreements are in compliance with the
requirements/provisions of other market
regulators like SEBI, IRDA, etc
• Check fee income recognized by the bank with
charges mentioned / agreed with the clients
• Carry out cut-off procedures and ensure
C.A. Parag Hangekar 58
Wealth Management & Third Party
Products
completeness of fee income recognized for the
year and accrue the earned income/commission
and defer income received in advance based on
services rendered
Third Party Products:
• Financial products that are sold by a bank for
some other Institutions. Banks only distribute or
sell these products on fee/commission/
brokerage basis.
• Examples of Third Party Products:
C.A. Parag Hangekar 59
Wealth Management & Third Party
Products
• Insurance Products
• Mutual Funds
• Collection of utility bills and taxes
• Investment Advisory Services
• Demat Accounts
• Agency Business, etc.
• Check approved policy in place detailing the
products and the manner in which they can be
and are sold
C.A. Parag Hangekar 60
Wealth Management & Third Party
Products
• Verify revenue earned on sale of these products
is properly accounted & received
• Verify compliances with GST & withholding tax
provisions while recognizing revenue
• For any outstanding receivables- check balance
confirmations from these third parties
• Any old outstanding should be verified for
disputes, appropriate provisioning or write-off
• Verify the income recognized by cross checking
data received from principals
C.A. Parag Hangekar 61
Thank you
62
C.A. Parag Hangekar

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Bank branch concurrent audit

  • 1. Practical Guidance on Verification of other areas in Concurrent Audit - 13 August, 2022 C.A. Parag Hangekar E-mail: phangekar@gmail.com Cell: 9820577913
  • 2. Income Verification • Interest Income – CC, OD, DL, TL, Bills Purchased & Discounted, overdue and penal interest, interest subsidy/ subvention etc. • Commission & Fees: – Bills for collection – Remittances & transfers – LCs & BGs – Processing fees – Lead Bank fees – Mobile banking fees – SMS charges on quarterly basis – Credit/ Debit card annual fees – Locker Rent – Govt business – CERSAI, CIBIL, Insurance, Penal charges C.A. Parag Hangekar 2
  • 3. Interest Verification • On test check basis interest debited by CBS should be checked manually through product rate sheets. • Checking the interest run reports • Booking of interest on credit card portfolio. • Booking of interest on Pool Accounts – Reversal of interest on compounded basis instead of simple interest basis. • Checking the movement in the interest rate changes in the master. C.A. Parag Hangekar 3
  • 4. Income Leakages • Checking of Borrower’s Master in the CBS with the Sanction terms & conditions. – Sanctioned rate of interest varies from the ROI entered in CBS. – Borrowers sanctioned interest at 6 months, 3 months and 1 month MCLR/ RLLR. System does not update the interest rate automatically in such cases, whenever the MCLR/RLLR is changed by the Bank. Branch needs to manually monitor and update interest rates in CBS. – In case of CC facilities, MCLR/RLLR rate is required to be reset on annual basis, however it got changed within a short period of 2-3 months. Change in Interest rate was occurring whenever there was any alteration done in the master of client (e.g. loan master was changed due to interchangeability of Fund based & Non - fund based limits. CBS was taking up fresh MCLR/RLLR as on date of master alteration.) C.A. Parag Hangekar 4
  • 5. Income Leakages – Restructured cases: • High number of cases under COVID/ MSME circulars • Renegotiated interest, repayment schedule not properly updated in CBS. • Wrong interest being charged. • Carving out of FITL • Moratorium in the principal and interest but usually the borrower is supposed to pay the interest on FITL – many branches skip this point & account turns NPA – Charging of penal interest on delayed submission of stock statements, Quarterly information statements, overdrawing of limits, ad hoc limits etc. – Rate changed in between the months and again amended as per sanction at the end of the month. C.A. Parag Hangekar 5
  • 6. Bills Purchased and discounted • Check the interest booking based on the tenure of the bills • Check the accounting policy of the bank • Reversal of interest in case of unexpired period – Rebate on Bills Discounted – interest booked upfront and then apportioned over the tenure of the bills. • Accrual of interest in case of overdue period – bills not crystallized on the due dates – interest to be booked for the overdue period. C.A. Parag Hangekar 6
  • 7. Bills Purchased and discounted • Bill Purchased on 1.2.22 for 90 days i.e. maturity date is 1.5.22. Income to be accounted till 31.3.22 and remaining to be reversed to Rebate On Bills Discounted. • Bill Purchased on 1.12.21 for 90 days i.e. maturity date is 28.2.22. Income to be accrued on the overdue period for the month of March 22. C.A. Parag Hangekar 7
  • 8. LCs/ BGs Commission • Confirm the accounting policy of the bank • Ascertain the period of the LCs/ BGs • Verify the interest rate from the sanction and the rates as per the circular • For BGs confirm the booking of the commission income upfront/ spread over the tenure of the BG as per the policy • Check the reversal of the expired BGs • Income booked on LCs based on their tenure • Confirm that the devolved LCs are debited to the CC account of the borrower C.A. Parag Hangekar 8
  • 9. LCs/ BGs Commission • Check the controls over the issue of the LCs and BGs from the relevant module of the CBS • Instances of issuing BGs by staff from excel – fraudulent transactions • Confirm the sequencing and the authentication of the documents • Verify the supporting for the LCs and the BGs issued to confirm the genuineness. • Ascertain the margins on the BGs as per the Bank circular and the sanction letters. C.A. Parag Hangekar 9
  • 10. Suspense & Sundry accounts • Temporary parking accounts • Usually deposits to landlords, advances to staff such as festival, traveling etc. shown under Suspense. Frauds, cash shortage etc. • To check there are no old and non-moving entries under these heads. Appropriate provision has been done for such items. • Fraud/ manipulation prone area so auditor needs to be cautious and constant monitoring of these accounts is required. C.A. Parag Hangekar 10
  • 11. Suspense & Sundry accounts • Ensure that multiplicity of accounts and unnecessary accounts are not opened as suspense accounts • Verify the process of expeditious clearance of items debited to suspense account and whether the same are actually cleared • Verify whether any office account is used for allowing debits to accommodate temporary overdrafts without appropriate disclosures • Since fraud prone hence constant checking is essential. C.A. Parag Hangekar 11
  • 12. Staff accounts • Auditor to keep check over the high value transactions in the staff accounts • Debit and credit turnover can be checked in the accounts to confirm that the same is in alignment with the income of the staff member • Fraud/ manipulation prone area • RBI has observed several frauds through these accounts. • Constant monitoring is required C.A. Parag Hangekar 12
  • 13. Inoperative accounts • Review of inoperative/ dormant accounts • Sudden operations to be checked properly with due authorizations • Maker Checker to be verified • Again, a fraud prone area since without proper controls the amounts in these accounts can be siphoned away – also can be used for manipulations – NPA window dressing. • Charges to be verified for non-operation of the accounts. • As per RBI Guidelines, no penal charges are to be levied for non-maintenance of minimum balances in any inoperative account C.A. Parag Hangekar 13
  • 14. Transfer to DEAF • The RBI vide its circular no. DBOD.No.DEAF Cell. BC.101/30.01.002/2013-14 dated March 21, 2014 issued “The Depositor Education and Awareness Fund Scheme, 2014 under Section 26A of Banking Regulation Act, 1949” • Credit balances lying older than 10 years to be transferred to DEAF by the Bank • Check the ageing of the credit balances lying in different accounts and confirm the transfer • CBS sometimes fails to identify savings accounts/ FDRs which were linked to LAD C.A. Parag Hangekar 14
  • 15. Transfer to DEAF (a) savings bank deposit accounts; (b) fixed or term deposit accounts; (c) cumulative/recurring deposit accounts; (d) current deposit accounts; (e) other deposit accounts in any form or with any name; (f) cash credit accounts; (g) loan accounts after due appropriation by the banks; (h) margin money against issue of Letter of Credit/Guarantee etc., or any security deposit; (i) outstanding telegraphic transfers, mail transfers, demand drafts, pay orders, bankers cheques, sundry deposit accounts, vostro accounts, inter-bank clearing adjustments, unadjusted National Electronic Funds Transfer (NEFT) credit balances and other such transitory accounts, unreconciled credit balances on account of Automated Teller Machine (ATM) transactions, etc.; (j) undrawn balance amounts remaining in any prepaid card issued by banks but not amounts outstanding against travellers cheques or other similar instruments, which have no maturity period; (k) rupee proceeds of foreign currency deposits held by banks after conversion of foreign currency to rupees in accordance with extant foreign exchange regulations; and (l) such other amounts as may be specified by the Reserve Bank from time to time. C.A. Parag Hangekar 15
  • 16. Interest booking on Overdue TD • RBI circular no. DBOD No. Leg.BC.34/ 09.07.005/2008-09 dated August 22, 2008 • Savings interest rate to be booked for overdue Term Deposits • Check the ageing of such deposits from the CBS • Check the working of the interest being booked on these deposits • Interest on overdue deposits – example of old scheme deposits – out of CBS and done manually in excel – check the accuracy of calculations C.A. Parag Hangekar 16
  • 17. KYC and AML • Compliance of KYC norms at the time of opening of CASA or Term deposit accounts • Application of rate of interest as per the interest table to every product of deposits by taking sample accounts of each type of deposit product including instances of premature withdrawal of deposits and retrospective renewal of deposits • TDS flag is correctly configured wherever Form 15G/15H has been received by the Bank and that TDS as per the rates in force has been deducted on interest payments C.A. Parag Hangekar 17 194A Interest from a Banking Company/ Post Office (Other than on Securities) Rs. 40,000 per annum for Others /Rs. 50,000 per annum for Senior citizen 10%
  • 18. KYC and AML • Application of various charges on CASA, e.g. Minimum Balance charges etc., on test check basis and compliance thereof • The accounting effects of interest payable in the form of interest accrued but not due and interest accrued and due are correctly given as also TDS compliances thereon • Compliance with internal circulars of the bank in terms of categorisation of customers, and application of the said terms in the master data of such deposit holders C.A. Parag Hangekar 18
  • 19. KYC and AML • The complaints lodged w.r.t. the customer services and contingent liability / liability arising thereon • Major movements in interest expenses vs. movements in interest bearing deposit Data Integrity & Modifications • Authorisation & control processes to ensure that the customer accounts opened in the system are properly updated in the relevant module in CBS. • Verify the correctness KYC data updated in CBS C.A. Parag Hangekar 19
  • 20. Exception reports checking • Obtain the list of exception reports prescribed by bank along with its periodicity for review • Whether the branch has followed the instructions issued by bank w.r.t. generation and verification of exception reports • Review of such transactions on sample basis will help in ascertaining the nature of the transactions and risk involved • Any issues which have not been complied / marked as pending compliance, status of the same should be obtained and reported. C.A. Parag Hangekar 20
  • 21. Exception reports checking • Obtain instructions issued by the bank for process to be followed when system generated data is manually altered. • Enquire about availability of audit trail / logs related to such manual interventions and review the same. • Data integrity: verify that the data being entered is done properly and there is proper maker checker principle for verification of the same • Instances of transactions reflected in Exception Reports: C.A. Parag Hangekar 21
  • 22. Exception reports checking • Ad hoc loans granted to borrowers • Overdrawing allowed over the limits • Changes in the interest rates not in line with the products defined in CBS • Major operations/ transactions in the newly opened accounts • Standalone Non Fund Based Limits granted to customers • Backdated updation of stock and book debt statements C.A. Parag Hangekar 22
  • 23. Exception reports checking • List of accounts wherein the facility is not renewed / reviewed • List of accounts slipped to NPA during the current period • List of accounts wherein there is an amendment in date of NPA • Loans below the benchmark rate • Loans above the maximum lending rate • List of accounts wherein re-phasement i.e. Change in EMI, Tenor, Moratorium period. C.A. Parag Hangekar 23
  • 24. Exception reports checking • CC Accounts with primary security as “Nil” • Manual debit/credits to Interest Income and Other Income Account • Manual debit to Interest Expense Account • FDs / RDs with aggregate balance at customer master level in excess of Rs. 20,000 and closed one / all FDs / RDs in cash • Cash Payments from Office Accounts in excess of Rs. 10,000 • List of Outstanding Office Accounts entries C.A. Parag Hangekar 24
  • 25. Exception reports checking • Bank Guarantees and LC Expired and not reversed • Resident Customers having Non Resident Account (under same or multiple customer master) • Status of the inoperative accounts • Unit Inspections pending for long • Manual debits to Inter office accounts • Login in CBS by personal on leave C.A. Parag Hangekar 25
  • 26. Inter office accounts – Fraud prone • Mostly used for internal business transactions of banks or transactions to facilitate movement of funds in a flow of transaction. • Reconciliation of transactions on a daily basis • Keep a track on un-reconciled transactions • Major transactions which occur through inter- office accounts: • Payment to / receipts from other branches of the proceeds of instruments received/sent for collection /realization/clearing C.A. Parag Hangekar 26
  • 27. Inter office accounts – Fraud prone • Cash sent to/received from other branches • Payment of instruments like gift cheques/ banker’s cheques/ interest warrants/ dividend warrants/repurchase warrants/refund warrants • Government receipts and payments handled by the banks • Operations by the authorized branches on the bank’s NOSTRO accounts through the Treasury/ International Banking Division • Transactions through NEFT, RTGS, NACH, UPI C.A. Parag Hangekar 27
  • 28. Inter office accounts – Fraud prone • Internet based transactions • Credit card related transactions of the customers • ATM transactions of the customer • GST transactions of bank branches within a zone and Zonal or Head office • TDS of the branches deposited by the central office • Parking of subsidies received from Government under various schemes C.A. Parag Hangekar 28
  • 29. Inter office accounts – Fraud prone • Verify the balance in this head and should seek explanation why the balance is not reconciled, if any • Unauthorized/ Objectionable practices in the Inter Office Accounts leads to Fraud. Illustrative instances of such practices are as follows: Ø Deficiencies in linking the office accounts to the Trial Balance and General Ledger Ø Disguising cash transaction of customer to avoid AML reporting Ø Disbursal of loan or repayment of loan resulting C.A. Parag Hangekar 29
  • 30. Inter office accounts – Fraud prone in misuse of funds and window dressing • Lack of automation for identifying and reporting of the outstanding entries • Opening of saving and current account and funds movement thereon misused through office accounts • Crediting a dummy entry by debiting the office account to the credit of borrowers account and then debiting so as to prevent from becoming NPA • Many income accounts do not have debit freeze C.A. Parag Hangekar 30
  • 31. Inter office accounts – Fraud prone • Review the system of operation for sensitive office accounts • Check all material transactions outstanding in office accounts even if it is outstanding for more than 6 months • Verify whether the transactions in accounts are matching with the purpose of account for which it is created • Reversal entries are made under proper authority & after due explanation and evidence C.A. Parag Hangekar 31
  • 32. Early Warning Signals (EWS)- as per RBI • EWS are those which should alert the bank officials about some wrongdoings in the loan accounts which may turn out to be fraudulent • An illustrative list of some EWS as per RBI Directives: • Default in undisputed payment to the statutory bodies as declared in the Annual Report • Bouncing of high value cheques • Frequent change in the scope of the project to be undertaken by the borrower C.A. Parag Hangekar 32
  • 33. Early Warning Signals (EWS)- as per RBI • Delay observed in payment of outstanding dues • Frequent invocation of BGs and devolvement of LCs • Invoices devoid of GSTN and other details • Dispute on title of collateral securities • Funds coming from other banks to liquidate the outstanding loan amount unless in normal course • Funding of the interest by sanctioning additional facilities C.A. Parag Hangekar 33
  • 34. Early Warning Signals (EWS)- as per RBI • Critical issues highlighted in the stock audit report • Exclusive collateral charged to a number of lenders without NOC of existing charge holders • Liabilities appearing in ROC search report, not reported by the borrower in its annual report • Frequent request for general purpose loans • Frequent ad hoc sanctions • High value RTGS payment to unrelated parties • Heavy cash withdrawal in loan accounts C.A. Parag Hangekar 34
  • 35. Early Warning Signals (EWS)- as per RBI • Not routing of sales proceeds through consortium/ member bank/ lenders to the company • Significant movements in inventory & receivables, disproportionately differing vis-à-vis change in the turnover • Non production of original bills for verification upon request • Significant increase in working capital borrowing as percentage of turnover C.A. Parag Hangekar 35
  • 36. Early Warning Signals (EWS)- as per RBI • Increase in fixed assets, without corresponding increase in long term sources (when project is implemented) • Frequent change in accounting period and/or accounting policies • Claims not acknowledged as debt • Material discrepancies in the annual report • Substantial related party transactions • Substantial increase in unbilled revenue year after year C.A. Parag Hangekar 36
  • 37. Early Warning Signals (EWS)- as per RBI • Large number of transactions with inter- connected companies and large outstanding from such companies • Resignation of the key personnel and frequent changes in the management • Significant reduction in the stake of promoter /director or increase in the encumbered shares of promoter/director • Raid by Income tax /sales tax/ central excise duty officials C.A. Parag Hangekar 37
  • 38. Cash Verification • Physical verification on surprise basis of cash at branch and ATM along with safekeeping and custody. • Ensure that there is no accumulation of large stocks of heavy cash and cut/mutilated/soiled notes, which otherwise need to be reported. • If cash holdings are beyond the prescribed cash retention limit, the same also need to be reported. C.A. Parag Hangekar 38
  • 39. Cash Verification • The concurrent auditor would also need to verify whether cash is promptly remitted to the currency chest or to RBI and need be reported if the same is not being so deposited. • Short or excess cash, that needs to be reported • Daily cash transactions, particularly any abnormal receipts and payments. • Surprise verification of cash by an officer other than the joint custodian. C.A. Parag Hangekar 39
  • 40. Cash Verification • Proper accounting of and availability of insurance cover for inward and outward cash remittances. • Accounting of currency chest transactions and delays/omission in reporting to RBI. • Reporting of Counterfeit Currency. • All cash transactions of Rs. 10 lakh and above reported in CTR (cash transaction report). • That all cash transaction of Rs. 50,000 and above invariably indicate Pan No./Form 60. C.A. Parag Hangekar 40
  • 41. Cash Verification • RBI has issued Master Circular on the Scheme of Penalties for bank branches including currency chests based on performance in order to ensure that all bank branches provide better customer service to members of public with regard to exchange of notes and coins, in keeping with the objectives of Clean Note Policy. C.A. Parag Hangekar 41
  • 42. Manual reversal of income • Obtain Trial Balance and Profit & Loss of the branch for month end • Check any negative balances appeared in above – now a days separate ledgers for control purpose. • Verify the income heads & understand nature and processing of transactions • If manual intervention observed - verify computation, sanction/approval from the Controlling Authority for such reversal • Instances of manual reversal of income: C.A. Parag Hangekar 42
  • 43. Manual reversal of income • SCA or SBA suggested- classification of advances leads to manual reversal non-served interest & charges • Excess charging of processing fee, documentation fee, inspection charges, commission fees, etc. to the borrower account • Renewal charges and other incidental charges debited even though advances not renewed. • Several times the necessary approval is awaited from the Zone/ Head Office. C.A. Parag Hangekar 43
  • 44. Locker Rent • Check the accounting policy of the bank • Check whether rent automatically credited in CBS or manually done • If manually computed, should check thoroughly so as to avoid income leakages • Verify whether locker rent properly accounted in books as per bank’s service charges policy • Check amount of rent arrears, periodicity and same should be reported • Obtain the report from CBS of the lockers sanctioned and the income booked – usually in the first quarter of the F.Y. amount is recovered from savings/current account. • Check whether done centrally or at branch level. C.A. Parag Hangekar 44
  • 45. Housekeeping • Sharing of passwords – controls • Storage of servers, switches, routers – access to them restricted? • Preservation of branch records/daily vouchers • Scrutiny of day to day vouchers • Reporting of fraud prone areas • Report on customer service • Irregularities of earlier audit not rectified • Banks accounts – Bank account reconciliation • Government Business- Pension payments, PPF, Collection of tax, other Govt. business, etc C.A. Parag Hangekar 45
  • 46. Housekeeping • Follow up laid down procedure w.r.t. security forms such as Drafts, Pay Order, FDR, etc. • Recovery of TDS on applicable TD, payment to contractors/landlords • Holding customer service meeting at periodical interval for requesting customers of all categories (Deposit, Advances, Forex) • Security at the Branch – Gun license • Ghosh Jilani Report – detailed questionnaire C.A. Parag Hangekar 46
  • 47. Main expenses to be verified • Plan the audit procedures based on control testing for accounting and recording of items of expenses correctly • Check accounting policy as well • Verify maker checker existence • Verify whether sanction/authorization for expenses done as per delegated powers • Confirm that the expenses incurred pertain to the official business of the branch • Rent, Telephone, Electricity, Travelling, Printing & Stationary etc. C.A. Parag Hangekar 47
  • 48. Forex & Remittances • Verify genuineness of foreign inward remittances, end use and purpose thereof • From the view point of Money Laundering • Foreign outward remittances particularly for import transactions to ascertain the genuineness by verifying the import bill of entry evidencing import of goods • Check the related booking of income – charges and the commission for the conversion. • Confirm that rate is proper as given by Treasury C.A. Parag Hangekar 48
  • 49. Forex & Remittances • Verification of SWIFT messages covering inward remittances whether such messages are authenticated properly and received from the Bank’s authorized overseas correspondence banks • Outward SWIFT messages: Verify whether outward messages are sent to the correspondent bank with authentication • SWIFT messages so received/sent are properly authenticated and their stamp authenticated & Signed by authorized officials. • Daily reconciliation between the Swift system and the data entered in CBS (PNB Fraud). C.A. Parag Hangekar 49
  • 50. Timely receipt of stock statements • As per sanction terms of advances check stock statements properly updated in CBS • Ensure that stock statements are received on or before the given due date. • Verify the date stamp on the stock statements and cross verify the date entered in CBS. • In the event of non receipt of stock statements, penal interest should be recovered from the due date till the date of actual receipt and report the same. C.A. Parag Hangekar 50
  • 51. General Points • Reconciliation of the Government Business accounts • Multiple CIFs – credit card accounts. • Closure of Deposits to be credited to loan accounts ONLY • Compliances on the observations – persistent irregularities • Debit balances in savings accounts – ATM withdrawals and UPI payments permitted • ECS charges debited in accounts even when there is no balance C.A. Parag Hangekar 51
  • 52. Fixed Assets, Current Assets & Current Liabilities • Fixed Assets – coding and updation of the FAR • Ensure that figures as per the trial balance from CBS matches with the schedule of Fixed Assets figures If different software maintained. • Check depreciation on fixed assets calculated as per bank’s defined policy & ensure proper accounting in CBS. • Verify date of recording the fixed asset in the books of accounts and commencement of depreciation which should be from the date, the asset available for use in line with AS-10 C.A. Parag Hangekar 52
  • 53. Fixed Assets, Current Assets & Current Liabilities • Ensure that assets are properly insured with bank clause inserted in the policy proper valuation thereof supported by original invoices • Ensure delegation of power in purchase and sales of fixed assets • Examine the evidence of physical existence of fixed assets • Current Assets & Liabilities: • It includes advances made to Staff, Tax paid in advance/tax deducted at source, Sundry C.A. Parag Hangekar 53
  • 54. Fixed Assets, Current Assets & Current Liabilities • Debtors with bifurcation thereof, Inter-office adjustments (net), Stationery and stamps • Check periodicity of outstanding sundry debtors/creditors • Physical verification of stationery & stamps, age wise breakup of pending entries inter-office adjustment account with reason thereof. • Check provision entries parked in other liabilities. C.A. Parag Hangekar 54
  • 55. Security Valuation and updation in the System – apportionment among various limits • Check value of securities pledged/hypothecated/mortgaged to the bank properly updated in CBS • Verify value properly apportioned among all facilities availed by single borrower • Verify whether there is no double entry of same securities value which results into overstatement of valuation against advances • Confirm the security valuation properly in case of NPA accounts • Check that latest value is updated • Verify if primary security value exists in D1/D2/ Loss accounts C.A. Parag Hangekar 55
  • 56. Security Valuation and updation in the System – apportionment among various limits • In case of vehicle whether the depreciated value is being considered. • Collaterals are stated as per valuation report which is not older than 3 years. • In case of consortium accounts only the portion of securities pertaining to the Branch have been updated in the security value fields. • Verify the statutory audit and stock audit reports to check for any qualifications pertaining to stock and assets and mention the appropriate revisions in your audit report to the Branch. C.A. Parag Hangekar 56
  • 57. Funding of FITL accounts • Manual transfer by the branches • During cut off period – treatment • Provisioning not done • FITL opened in different code • Check the sanction and confirm that the master has been properly updated with the terms and conditions of ROI and the repayment schedule. • Ensure that interest is serviced as and when due by the borrower. C.A. Parag Hangekar 57
  • 58. Wealth Management & Third Party Products Wealth Management • Check client service agreement with wealth management clients • Check that the terms of such service agreements are in compliance with the requirements/provisions of other market regulators like SEBI, IRDA, etc • Check fee income recognized by the bank with charges mentioned / agreed with the clients • Carry out cut-off procedures and ensure C.A. Parag Hangekar 58
  • 59. Wealth Management & Third Party Products completeness of fee income recognized for the year and accrue the earned income/commission and defer income received in advance based on services rendered Third Party Products: • Financial products that are sold by a bank for some other Institutions. Banks only distribute or sell these products on fee/commission/ brokerage basis. • Examples of Third Party Products: C.A. Parag Hangekar 59
  • 60. Wealth Management & Third Party Products • Insurance Products • Mutual Funds • Collection of utility bills and taxes • Investment Advisory Services • Demat Accounts • Agency Business, etc. • Check approved policy in place detailing the products and the manner in which they can be and are sold C.A. Parag Hangekar 60
  • 61. Wealth Management & Third Party Products • Verify revenue earned on sale of these products is properly accounted & received • Verify compliances with GST & withholding tax provisions while recognizing revenue • For any outstanding receivables- check balance confirmations from these third parties • Any old outstanding should be verified for disputes, appropriate provisioning or write-off • Verify the income recognized by cross checking data received from principals C.A. Parag Hangekar 61