Statutory Branch Auditing of Banks: Using CBS Reports
Regulatory Mandate & Revised LFAR Framework
Statutory auditors of banks evaluate adherence of laws and regulations and policies / procedures / guidelines of the banks. RBI’s new directions on financial statements preparation and presentation vide circular DOR.ACC.REC.No.45/21.04.018/2021-22 dated August 30, 2021 fosters stringent financial reporting discipline amongst banks and enhance auditors’ responsibilities of evaluations of relevant controls. Long Form Audit Report (LFAR) provides a detailed analytical view of such adherence in banks’ systems and processes. Particularly, new LFAR provides auditors an opportunity to report on more financial and operational controls and also provides a best basis to approach the statutory branch auditing.
In current exceptions-based CBS control environment, audit evidences are preserved in the form of audit exceptions. Banks have their customized exceptions handing systems and analytical reports based on their MIS needs and legal/regulatory requirements. Article attempts to delve upon such audit exceptions / system generated analytical reports crucial for branch auditing that would help auditors meet their statutory audit obligations effectively.
Overview of CBS Environment & Core Applications
Currently, in public sector banks, following CBS applications are used:
Audit Exceptions / System Generated Reports Architecture:
Various audit exceptions/ system generated reports and their nomenclature and software menus are not uniform across the CBS environments and across the banks. In addition to the menu-driven CBS reports, different customized monitoring / exception handling systems are being followed by the banks and various audit exceptions/ monitoring reports are available on their specialized exceptions handling / monitoring portals. For example,
- Finacle Environment: Generally reports are menu-driven, however, various monitoring/ exceptions/ analytical reports have been customized and are on specialized portals. For example, in Bank of Baroda, most monitoring reports relevant for LFAR are available on CEMU (Centralized Exception Monitoring Unit) portal. In Punjab National Bank, such reports have been customized on MIS portals. In Union Bank of India, large number of such reports are available on credit monitoring and credit compliance (CMCC) portal.
- B@NCS Environment: Generally, for all daily exceptions / analytical reports, an ‘All in One’ daily folder is created and placed on users’ desktop.
- Flexcube Environment: Such exceptions/ analytical reports are largely available as periodical reports (e.g. daily, monthly, quarterly) for monitoring purposes.
FINACLE 10 Reports: Comprehensive Menu Directory for Branch Audit
| S. No. | Information required for audit / Reports | Menus |
|---|---|---|
| I | BALANCE SHEET | |
| Assets | ||
| 1 |
Shroff Cash Report: (Denomination-wise cash balance report for physical verification of cash) |
HSCWRPT |
|
Cash Balance Report: (To check average cash holdings and cash in excess of cash retention limit) |
HCBR | |
| 2 | Advances | |
| Appraisal: | ||
| New Accounts opened during the period (For selection of sample of loan and deposit accounts) | HACSP | |
| Loan Account Master Print (To verify the interest rate, DP and other items) | HLAMP | |
| Asset Classification Reports (To check asset classification history of the accounts) | HASSET / HASSCR | |
| Interest Table History (To check interest rates and their modifications) | HINTTM | |
| Account Limit History (To check DP calculation and for frequent /renewal of limits, if any, in the system) | HACLHM | |
| Review / Monitoring / Supervision: | ||
| Limit Accounts Review Overdue Report | HLAROR | |
| Stock Statements Submitted Position | STKSTMT | |
| NPA Reports | HNPARPT | |
| Accounts restructured/re-phased | HLARA | |
| Loan Balancing Reports/ Jotting Reports | HBR / JOTRPT | |
| TOD/Excess/ Ad hoc Allowed | HTODRPT | |
| Debit Balances In SB/CD | HBR | |
| Insurances Expired | INSEXPD | |
| Loan Accounts Overdue Position Inquiry /Stressed /PNPA | HLAOPI | |
| Loan Accounts Repayment Schedule | HLARSH | |
| Account Turnover Report (CC-OD accounts) | HATOR | |
| Bills Purchased/Discounted | HBPR | |
| 3 | Non-Fund Based Business | |
| Guarantee Issued & Liability Register | HGILR | |
| Guarantee Expired But Not Reversed | HGENR | |
| Guarantee Invoked But Not Paid | HGIPNP | |
| Documentary Credits Liability Register | HDCLIABR / DCREG / DCSTMT / DCLIABRG | |
| Documentary Credit General Purpose Report | HDCGPR | |
| 4 | Other Assets | |
|
Minor Sub-Group Office Items Report: For age-wise and entry-wise break up of outstanding in following GL sub-heads/ accounts:
|
HMSGOIRP | |
| II | LIABILITIES | |
| 1 | Other liabilities | |
|
Minor Sub-Group Office Items Report: For age-wise and entry-wise break up of outstanding in following GL sub-heads/accounts:
|
HMSGOIRP | |
| Inward Bills For Collection (IBC) | HBRCR | |
| Outward Bills For Collection (OBC) | HBRCR | |
| III | PROFIT & LOSS ACCOUNT | |
| 1 | Interest | |
|
Applied Interest Report: (To test-check the interest rates fed and to check whether interest have been applied in standard accounts only) |
HAINTRPT | |
|
Income Accounts Debited : Debits - Incomes GL-Subhead: (To check manual alteration/unauthorized reversals, if any) |
HFTR | |
| Interest Adjustment Record /Report | IARMREP | |
| Manual Interest Applied Report | HMINTRPT | |
| Interest Provision | INTPRO | |
| IV | GENERAL | |
| 1 | Gold / Bullion & Security Items | |
|
Inventory Status Report: To physically verify the inventories of sensitive stationary/ security Items, e.g. cheque Books, FDRs, obtain reports for all locations / custodians:
|
HISRA | |
| 2 | Books & Records | |
Exceptional Transactions Reports (ETRs):
|
HEXCPRPT | |
| 3 | Other Reports | |
| General Reports (Balance sheet, Profit & Loss, GLB, Weekly etc.) | HGR1 / MISRPT | |
| Financial Transactions Reports | HFTR | |
| Inquiry on GL transactions | HIOGLT / HIOT | |
| Customer Accounts Statements | HPSP | |
|
Office Accounts Statements: (For GL/PL accounts, e.g. sundries, suspense, incomes and expenditures accounts) |
HACLPOA | |
| TDS Reports | HTDSIP / HTDSREP | |
| TDS Amount Slab Table Inquiry | HASTI | |
| 4 | FOREX Business | |
| Packing Credit- Party Wise Pre Shipment Credit | RPODPC | |
| Overdue Pre-shipment Credit Report | GOPCR | |
| Export and Outward Bills Report | HEOBR | |
| Statement of Overdue Import/Inward Bills | HOIIB | |
| Foreign Bills Balancing Register | HFBBR | |
| Bills to be Delinked Statement | HBDS | |
B@NCS Reports: Critical Files & Audit Workflows (SBI, Indian Bank, CBI, BOM)
| S. No. | Information required for audit/ Reports | Menus / Reports |
|---|---|---|
| 1 | Closing GLBs / Trial Balances |
OGL- detailed trial balance / BALSHT as on date / weekly as on date (Detailed trial balance for March could help identify March month transactions) |
| 2 | Balances / Jottings Reports | Loan balance file |
| 3 | Financial Transactions Inquiry / GL / Impersonal Accounts Transactions |
Audit BGL reports / Flabby_AC_Report, System_suspense_report, agewise break up and GL outstanding accounts report. Transfer_supplementary_report Supplementary_control / GL Day book / GL-Outstanding-Accnts |
| 4 | Impersonal (Office) Accounts - Outstanding Items Report | Audit BGL reports / Flabby_AC_Report, System_suspense_report, agewise break up and GL outstanding accounts report |
| 5 | SMA / Potential NPA accounts Reports | PNPA / SMA Reports, / Irregular Excess drawing / Standard Accounts irregular excess drawal, SMA-0, SMA-1, SMA-2 reports |
| 6 | Asset Classification / Non- performing Assets (NPA) Reports | NPA_report |
| 7 | Restructurings / modifications in Limits (e.g. changes in repayment schedule) Reports | DL/TL-A&S-Loan Processing-Generate Repayment Schedule- Action – E |
| 8 | Sensitive stationary / security items - Valuable Paper Inventory System | VPIS |
| 9 | Various day-end reports | EoD, BoD reports / user maintenance / Exceptional_transactions_report |
| 10 | TDS / Customer-wise TDS report | Customer-wise tax deduction report |
| 11 | Other Useful Reports / EOD Reports |
• Credit Monitoring & Recovery:
• Loan Reports:
|
Flexcube Reports: Critical Monitoring & Periodical Directories (Canara Bank)
| S. No. | Information required for audit/Reports | Menus / Reports |
|---|---|---|
| 1 | Closing GLBs / Trial Balances |
GL Report, GL Tally Report, Day book cum trial balance (GL Alert Report indicates the entries, if any, outstanding unadjusted) |
| 2 | Balances / Jottings Reports | Balances reports (scheme-wise) |
| 3 | Financial Transactions Inquiry / GL / Impersonal Accounts Transactions | EOD reports- General Ledger Statement- SA |
| 4 | Impersonal (Office) Accounts - Outstanding Items Report | General Ledger Statement- SA (Sundry Assets) |
| 5 | SMA / Potential NPA accounts Reports |
Periodical Reports- List of NPA accounts/ Consolidated NPA position SMA-0, SMA-1, SMA-2 reports SWL (Special Watch List) |
| 6 | Asset Classification / Non- performing Assets (NPA) Reports | Periodical Reports- List of NPA accounts/ Consolidated NPA position |
| 7 | Inventory Status Report (Sensitive stationary/ security items/Valuable Paper Inventory System) | Branch Inventory Report |
| 8 | Various day-end reports | EOD Reports |
| 9 | Other Useful Reports / EOD Reports |
|
Special Audit Considerations: Detecting Window-Dressing & Ever-Greening Malpractices
“Banks shall ensure that balance sheet and profit and loss account reflects true and fair picture of its financial position. Instances of window dressing of financials, short provisioning, misclassification of NPAs, under-reporting/ incorrect computation of exposure/risk weight, incorrect capitalization of expenses, capitalization of interest on NPAs, deliberate inflation of asset and liabilities at the end of the financial year and subsequent reversal immediately in next financial year, etc. shall be viewed seriously and appropriate penal action in terms of the provisions of the Banking Regulation Act, 1949 shall be considered”.
Following are few of the critical Finacle system reports that would help evaluate potential window-dressing / ever-greening malpractices and non-compliance, if any:
• HFTR (Financial Transactions Reports)
HFTRHFTR menu in Finacle 10 provides different Types of entries (viz. Cash, Clearing and Transfer) – Bank-Induced and Customer-Induced. It provides reports at GL heads / GL subheads /account levels. It provides reports for different amount ranges and account ranges and for the periods. Particularly, Bank Induced (BI) Transfer entries would help indicate potential fictitious (merely book-entries), if any, routed through these accounts. For example:
- Ever-Greening of NPAs / Weak Accounts: HFTR report on ‘Bank-Induced (BI) Transfer type Credit’ entries in CC/OD GL subheads for March could help identify merely book-entries, if any, with corresponding Debit entries in impersonal accounts (e.g. sundry deposits, sundry credits) and subsequent reversal thereof, in ‘No Turnover’ / ‘Poor Turnover’ CC/OD accounts to evergreen NPAs /week credit facilities.
- Year-End Balance Sheet Inflation (Window-Dressing): HFTR report on ‘Bank-Induced (BI) Transfer type Debit’ entries in CC/OD GL subheads at year-end could help identify entries, if any, in unutilized CC / OD limits with corresponding Credit entries in deposit accounts and subsequent reversal thereof after year-end, and could help indicate potential window-dressing, if any.
• HLARA (Loan Accounts Restructured) & HACI Inquiry
HLARA / HACIThis report provides information on number of times a loan account has been rescheduled / restructured. ‘Schedule No.’ shown indicates the number of times, limit /repayments have been reschedule / restructured. For example, inquiring information, such as, for top 10 accounts appearing in SMA-2 of December would help identify the accounts, if any, wherein repayments have been re-phased frequently/ irregularly to evergreen the loan accounts. In HACI, menu, E option, would also help provide repayment rephasements Details- for individual inquiry. This is an account specific menu, hence auditors could use this for top -5 / large/SMA accounts.
• HMSGOIRP (Minor Sub-Group Office Items Reports)
HMSGOIRPThis report provides age-wise details of outstanding entities in office/ impersonal accounts (e.g. Sundry Deposits, Sundry Credits, Suspense, inter-branch) and would help obtain age-wise and entry-wise details of entries outstanding in such accounts and auditors could ascertain reasons for such long outstanding.
• HTDSIP / HTDSREP (TDS Reports) & HASTI Slab Inquiry
HTDSIP / HASTIThis menu provides various TDS reports including ‘TDS Summary’ enabling verification of TDS deduction and remittance on eligible amounts. To obtain TDS information for a specific constitution code (i.e. companies, individuals), HASTI menu report would help provide such information to check and determine non-compliance, if any.
• HEXCPRPT (Exceptional Transactions Reports - ETRs)
HEXCPRPTThis provides exceptions (financial and non financial) encountered At a SOL/By a SOL/Of a SOL (Service OutLet) during the day. Generation and scrutiny of exceptional transactions reports (ETRs) by the branch, recording the post-facto authorizations for exceptions, is mandatory in terms of RBI Circular No. DBS. CO.FrMC. BC.No.10 /23.04.001/2010-11 dated May 31, 2011 ‘Findings of Forensic Scrutiny- Guidelines for prevention of frauds’.
Word of Care for Branch Auditors:
- It is quite possible that exact menu / nomenclature of the report might be different than mentioned here. Therefore, it is strongly suggested that auditors should check with the bank for CBS application used and obtain the relevant reports available in the CBS environment.
- While using Finacle 10 generally ‘H’ is prefixed with the menu. Of the menu options mentioned above, some might work in DC (Finacle Core) environment while others may work in DR environment. In ‘SEARCH’ menu, any report, which is not specified in the menu list, could be searched by putting key words in search field.
- In B@NCS: TL = Term Loan, DL = Demand Loan, A&S = Accounts and Services, L = Long, E = Enquiry.
Conclusion
While using such audit exceptions / system generated reports, auditors need to apply heightened professional skepticism. Some of the reports might need no further validation/ confirmation, while many of the system generated reports posing risk of manual intervention, need further validation by the auditors for their completeness and correctness such as, NPA, SMA, restructuring, stock statements pending, reviews /renewals overdue and inspections overdue reports. No standard and exhaustive list of menus/ reports could be provided here and cannot be a panacea for auditing of all bank branches. Overall, above are some of the generally available various audit exceptions/ system generated CBS reports providing a basis for auditing could work as a beginner’ guide.