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    SR.NO. SUBJECT

    1 NPA GENERAL

    2 NPA AGRICULTURAL ADVANCES

    3 LFAR

    4 CBS

    5 GHOSH JILANI

    6 DEPRECIATION

    7 GUARANTEES

    8 MOC

    9 TAX AUDIT10 STOCK AUDIT

    11 GENERAL

    i.TAXES COLLECTED

    ii.GENERAL - D.P. CALCULATION

    iii.INTEREST SUB-VENTION CLAIMS

    iv.AUDIT PROGRAMME & DOCUMENTATION

    v.EXTENSION OF TIME FOR AUDIT DUE TO HIGH VOLUME

    vi. RRB'S

    vii. MORTGAGE & ELIGIBILITY FOR LOAN

    viii.D.P. CALCULATIONix.DISCLOSOURE ACCOUNTING POLICY

    x.NEGATIVE LIEN

    INDEX

    FAQ'S ON STATUTORY AUDIT OF BANK BRANCHES

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    1 There is an instruction from the H.O. to branches to reverse

    the liability entries in the case of guarantees whose validity

    date has expired as on 31

    st

    March 2008 . This is being doneirrespective of the fact that the discharged original

    guarantees have not been received by the branch. The

    branch has written a letter to the beneficiary informing that

    as the guarantee is expired and is not renewed, they are

    canceling the guarantees. But if one goes by the wording of

    the guarantees issued, it appears that the liability of the

    bank will continue till it receives back the discharged

    guarantee from the beneficiary and the validity period

    restricts only the usability of the guarantee after the expiry

    period. Of course bank may do it keeping in view the

    requirements of Basel II norms. What should be the

    approach of the branch auditors in this case ?

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    As per bank policy, the bank is correct if it reverses bank

    guarantee as of 31st

    March because technically there is no liability

    after that date. However one key point is to be remembered thatthe liability lapses as on 31

    stMarch only at the closing hours of

    the day and it would be more prudent if the liability is reversed on

    1st

    April. The point of receiving the original guarantee is

    procedural and in no way affects the liability. However if there is a

    claim on the guarantee before 31st

    March and it would at least

    take a few days for the bank to know whether the guarantee has

    been invoked or not. Thus once again it would be more prudent to

    wait for sometime and in this case a months time is very

    reasonable. However since there is the bank policy to reverse of

    the contingent liability immediately he may have to follow that.

    However we ought to state that the same is not prudent and atleast the months wait is necessary. This matter may be bought to

    the notice of Central Statutory Auditors.

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    1

    Depreciation

    SLM

    Method

    Plant and Machinery 13.91% 4.75% 15% 50% of normal

    rate

    40.00% 16.21% 60% 50% of normalrate

    Fo r L es s th an

    180 days u se

    Data Processing Machines including

    computers

    The bank has charged depreciation on Computers @ 33.33% following SLM

    method. The asset was purchased at the fag end of the year, i.e., in

    December, 2007.

    Computers under RBI instructions, SLM method are followed. Therefore

    depreciation @ 33.33% should be charged even if used for less than 180

    days in a year.Computer software not forming integral part of hardware.

    Where the aggregate cost of individual items of plant and machinery costing

    Rs.5,000 or less constitutes more than 10% of total actual cost of plant and

    machinery rate of depreciation applicable to such items shall be the rates asspecified in item II of the schedule.

    As per Income Tax Act, "computer software" means any computer program

    recorded on any disc, tape, perorated media or other information storage

    devise.

    No rates of depreciation on fixed assets have been prescribed by the Banking

    Regulations Act, 1949. The provisions of the Companies Act, 1956 should

    therefore be kept in mind in this respect especially in so far as the banking

    companies are concerned. RBI has directed that in respect of computers and

    data processing equipments, depreciation be provided over three years

    period. The Banking Regulations Act, 1949 requires, in the case of other

    bank, the auditor should examine whether the rates of depreciation are

    appropriate in the context of the expected lives of the respective assets.

    Rate of depreciation as per companies Act and Income Tax Act.

    Descr ip t ion o f the Asset WDV

    Method

    I Tax Act

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    2

    3 Bank branch is charging depreciation on the items used at home being

    provided to its staff. The depreciation is allowed fully on this items.

    As per the provisions of Companies Act, 1956 "Where during any financial

    year, any addition has been made to any asset or where an asset has been

    sold, discarded, demolished or destroyed, the depreciation on such asset

    shall be calculated on a pro-ratabasis from the date of such addition or, as

    the case may be, up to the date on which such asset has been sold,

    discarded, demolished or destroyed.There is no specification as to the computer software that is not forming

    integral part of the hardware.

    Kindly advise if the bank's policy to write off the entire cost of software and

    33.33% of computers purchased in December, 2007 and not put to use for

    the entire year.

    If during the audit of FY 07-08, we found that one of the asset has wrongly

    been taken in 10% block instead of 15% block since FY 03-04 and it was

    overlooked by management and previous auditors. Then how presentstatutory auditor should dealt with this issue.

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    The bank can claim depreciation for the full year

    regardless of the date of purchase. Do not let the

    depreciation policy under other statutes confuse you.Since you have mentioned that the audit booklet

    also contains similar instruction, you can keep that

    as backing for your action.

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    You need to calculate the depreciation from

    F.Y.2003-04 at 15%. Difference in depreciation tilllast year need to be provided for by the

    management. You could give MOC to this effect and

    also give a note in your LFAR /main audit report

    If the amount involved is material, suggest

    memorandum of change and report that as prior

    period item.

    The auditor is not clear about the fact whether

    depreciation in question is allowable under whichact. Whether Income Tax Act or any other Act.

    So far as the depreciation on Items used at home

    being provided by the bank and they are as per the

    approved policy of the bank, the depreciation shall

    be charged at appropriate applicable rates

    prescribed by the bank.

    The depreciation shall be charged to the profit and

    loss account.

    Regarding disallowance under the Income Tax Act,

    the same shall be dealt with by the bank at the timeof filing of Income Tax Return at the Head Office.

    Auditor can mention the amount of depreciation on

    such items whether used for personal purposes and

    mention the same in form No. 3 CD which will be

    consolidated at the Regional / Zonal Office level.

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    Also the auditor can refer this point along with

    amounts of depreciation in Long Form Audit Report.

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    INTEREST SUB-VENTION CLAIMS

    RBI passes on 2% interest subvention to banks on crop loans

    where banks are required to charge interest @ 7% P.A. for

    crop loans disbursed up to Rs.3 lacs.

    We have noticed that one of our branches has been charginghigher rate of interest say 11 to 12% till September-October

    and thereafter it has started charging interest at 7%.

    As u know that we have to give certificate for interestsubvention for claiming the same from RBI. Moreover this

    subvention amount is worked at zonal office and they provide

    us list for certificate. We only test check because of bulk

    volume.

    In this particular case, we have asked manager to pass on

    interest subvention amount of 2% for kharif, i.e., April to

    September in stead of directly crediting to interest income andfor rabi i.e., October to March to be credited to interest income

    account.

    On account of large no of accounts, it is not possible for us to

    verify higher interest charged by bank in each and every case.

    Hence, we have worked out this short cut.

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    Whether this is right and what level of responsibility comes in

    providing certificate to RBI for claiming interest subvention in

    such case.

    MORTGAGE & ELIGIBILITY FOR LOAN

    What is the difference between Mortgage, Pledge and Lien

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    Who can avail facility of Overdraft and Cash Credit (CC a/c).

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    D.P. CALCULATION

    1. The bank which we are auditing has got the practice of not

    to deduct the sundry creditors while calculating the drawing

    power in the Cash Credit Account. According to the circulars

    issued by the Head Office only the creditors which are above

    the estimated level of creditors are to be excluded (whichinformation is never available with the branch at the time of

    allowing monthly drawing power). Our opinion of allowing

    Drawing Power only against the paid stock as prescribed by

    the Reserve Bank of India is not acceptable to the bank.

    TAXES COLLECTED

    The bank has included the amount of BCTT collected under

    "Miscellaneous Income" in the P & L account of the branches.

    It is specifically mentioned in "Others" of Miscellaneous

    Income column of the banks pre-printed P & L format. I feel

    that BCTT is a liability and can not be classified under income

    under any circumstances. What stand should I take in this

    regard. The amount involved is material.

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    The Branch has accounted for all service charges received

    gross (inclusive of Service Tax). No provision for Service tax is

    made at the branches because it is done at the HO level. But

    this has resulted in the overstatement of the branch income

    and under statement of liabilities to the extent of the amount ofservice tax. What stand should be taken in this regard?

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    As per my information, the Institute has not issued any

    separate guidelines for Statutory Audit of RRBs. In my view

    there are no special points, as such and our normal

    procedure for bank audit should be followed.You may refer to Guidance Note issued by the Institute on

    Audit of Banks. (including para 1.11 of Chapter 1 on RRBs

    of 2008 edition of the Guidance Note)

    At the end of the audit, the auditor has to give the reports

    and certificates. The report is a reasonable assurance and

    has two parts (mainly), the statement of facts and theexpression of opinion. The auditor has to plan his audit in

    such a fashion that he is comfortable in expressing his

    opinion. If the auditor gives the certificate without carrying

    out proper audit checks, it may lead to professional

    negligence. Thus the auditor may put in additional

    manpower to complete the audit properly. The need be he

    may talk to the bank about extension of time.

    Please give written representation to Bank. Please keep

    details of the work done so as to enable you to justify the

    work done and the time required. At the same time pleasehave a suitable team to assist you. Finally you must keep in

    mind that inadequate time is no justification for dilution of

    quality.

    There is no standard audit program. One may refer to the

    Guidance Note on Audit of the Banks issued by the ICAI.

    The ICAI has come out with the CD on bank audit which has

    certain check points in the bank audit. Moreover one may

    use LFAR as the guideline for carrying out the checking

    activities.

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    On documentation one may refer to the Auditing Standards

    on Documentation to build up the working paper file.

    Whether accounting of Interest Subvention claim should be

    made at the branch or at Zonal Office of the Bank, will

    depend upon the policy of the Bank under audit. In my

    opinion, passing of entries of subvention claim will depend

    upon this policy.

    2. As per the RBI circular dated 10th

    May 2007 on extension

    of subvention scheme for the year 2007-08, subvention shall

    be available to the public sector bank, on the condition that

    short term credit is made available to the farmers @ 7% p.a.

    If this condition is not followed by any branch of a bank,

    subvention shall not be available. In the cases cited by you,

    since interest is charged at the rates higher than the

    stipulated rate of 7%, such accounts shall not be eligible for

    subvention. In my opinion, these accounts should be

    excluded from subvention claim.

    3. The test check to be applied for verification of no. of

    accounts shall be a matter of judgment & decision of the

    individual auditor. An auditor may enquire whether data of

    rates of interest charged on all such accounts can be made

    available in electronic form. In such a case he can use

    Microsoft Excel tools to find out all such cases of incorrect

    rate of interest charged. He may decide to suitably qualify

    the certificate to be issued, based on the circumstances.

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    A mortgageis a conveyance or contract that pledges real or

    personal property as security for the performance of an

    obligation, usually the payment of a debt. The term comes

    from the Old French "dead pledge," apparently meaning that

    the pledge ends (dies) either when the obligation is fulfilled

    or the property is taken through foreclosure.

    In most jurisdictions mortgages are strongly associated with

    loans secured on real estate rather than other property

    (such as ships) and in some cases only land may be

    mortgaged. Arranging a mortgage is seen as the standard

    method by which individuals and businesses can purchase

    residential and commercial real estate without the need to

    pay the full value immediately. See mortgage loan for

    residential mortgage lending, and commercial mortgage for

    lending against commercial property.

    In many countries, it is normal for home purchases to befunded by a mortgage. In countries where the demand for

    home ownership is highest, strong domestic markets have

    developed, notably in Spain, the United Kingdom, and the

    United States.

    In law, a lienis a form of security interest granted over an

    item of property to secure the payment of a debt or

    performance of some other obligation. The owner of the

    property, who grants the lien, is referred to as the lienorand

    the person who has the benefit of the lien is referred to as

    the lienee .

    In the United States, the term lien generally refers to a widerange of encumbrances and would include other forms of

    mortgage or charge. In the U.S., a lien characteristically

    refers to non-possessory security interests (see generally:

    Security interest - categories).

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    In other common law countries, the term lien refers to a very

    specific type of security interest, being a passive right to

    retain (but not sell) property until the debt or other obligation

    is discharged. In contrast to the usage of the term in the

    U.S., in other countgries it refers to a purely possessory

    form of security interest; indeed, when possession of theproperty is lost, the lien is released, However, common law

    countries also recognise a slightly anomalous form of

    security interest called an "equitable lien" which arises in

    certain rare instances.

    In the U.S. and Canada the word is usually pronounced

    lien,whereas in other countries (the UK) is more normally

    enunciated as lien.

    Despite their differences in terminology and application,

    there are a number of similarities between liens in the U.S.

    and elsewhere in the common law world.

    Cash credit Account

    This account is the primary method in which Banks lend

    money against the security of commodities and debt. It runs

    like a current account except that the money that can be

    withdrawn from this account is not restricted to the amount

    deposited in the account. Instead, the account holder is

    permitted to withdraw a certain sum called "limit" or "credit

    facility" in excess of the amount deposited in the account.

    Cash Credits are, in theory, payable on demand. These are,

    therefore, counter part of demand deposits of the Bank.

    Overdraft The word overdraft means the act of overdrawing

    from a Bank account. In other words, the account holder

    withdraws more money from a bank account than has been

    deposited in it.

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    How does this account then differ from a Cash Credit

    Account? The difference is very subtle and relates to the

    operation of the account. In the case of Cash Credit, a

    proper limit is sanctioned which normally is a certain

    percentage of the value of the commodities/debts pledged

    by the account holder with the Bank. Overdraft, on the otherhand, is allowed against a host of other securities including

    financial instruments like shares, units of mutual funds,

    surrender value of LIC policy and debentures etc. Some

    overdrafts are even granted against the perceived "worth" of

    an individual. Such overdrafts are called clean overdrafts.

    There are many ways in which finance can be raised Cash

    Credit is one of the many ways of raising finance (i.e. it is a

    type of loan account).

    Meaning : Cash credit is an arrangement under which a

    customer of a bank or financial institution is allowed anadvance up to certain limit against credit granted by bank.

    That means a loan may be granted say for Rs. 1 Lakh

    however the customer/borrower of the loan may take the

    amount of loan to the extent required by him but not

    exceeding the limit of Rs. 1 Lakhs.

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    Purpose : The purpose for which loan is required is essential

    to ascertain, as for different purposes different types of loan

    can be taken. E.g., In case the loan is required to purchase

    fixed assets like plant and machinery, term loan must be

    taken as plant and machinery are long term assets it will

    take time in repayment of the loan and repayment can bedone in EMIs (Equated Monthly Installments). Where as a

    loan required for working capital needs a long term loan is

    not required as repayment does not require long period,

    hence cash credit may be availed. Explanation of Cash

    Credit loan facility : If for e.g., a person is having a

    business. To carry on this business he needs to purchase

    raw material, and sell the goods. For this he needs working

    capital to run his daily business. Working capital means

    current assets minus current liabilities. Where current assets

    comprise of investment in stock, sundry debtors, cash, etc.,

    current liabilities comprise of sundry creditors, suppliers of

    stock (incase of sto are short to address the repayment of

    the term loan over the sanctioned

    tenure?

    This working capital that is required to run the business can

    be either funded by the businessman himself or if he does

    not have the money he can take a loan i.e. Cash credit. In

    Cash Credit facility an amount of loan is given to the

    borrower/businessman for his working capital needs. The

    entire amount of working capital required is not funded by

    the bank, some small amount will have to be funded by the

    businessman and the balance amount will be funded by a

    bank as a loan. This is as per RBI rules. The amount of loan

    to be given is decided on the basis of different types of

    methods like MPBF (Maximum Permissible Bank Finance)suggested by Tandoon Committee or other methods. These

    methods use formulas which take into consideration actual

    working capital required.

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    The amount so worked out is given as loan and is called as

    limitthis is because under this kind of loan the borrower

    may not take up the entire amount of loan as working capital

    requirement every day is not the same.

    Any entity which is in a position to offer the sound security

    and undertakes to maintain financial discipline can avail ofthe overdraft/cash credit facility.

    If the drawing power calculated from paid stocks is

    significantly lesser than the outstanding on a continuous

    basis, the account can be classified as an NPA. The same

    can be done taking the fall in drawing power as nottemporary. Further, the shortfall in draw power due to

    reduction in creditors could imply fund divergence, which

    should be brought out. However most of the banks do not

    deduct creditors to arrive at paid stocks and thus calculate

    drawing power ignoring creditors. This issue has also not

    been qualified by RBI till date. Many Chartered Accountants

    have also ignored this fact and classified the same as

    Standard. However in my opinion, you can classify the same

    as an NPA & if the branch head is not agreeing to sign the

    MOC, leave it to the Central Statutory Auditor to decide

    giving the MOC & bringing out all facts clearly.

    Check the closing guidelines of the bank. If it states (or any

    other circular issued at the time of commencement of BCTT)

    that BCTT has to be accounted as "Income", then you need

    to report in the statutory audit report about the same and

    quantify it.

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    This is the usual method of accounting by many of the

    banks. Yes, you should report it in the statutory audit report

    about overstatement of income to that extent.

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    ISSUE

    NPA AGRICULTURAL ADVANCES:-

    1) As regards Agricultural advances, they become NPA

    when the principal and interest remains overdue for two crop

    seasons. For the area covered by the branch they are

    contending that Paddy cultivated comes under one cropping

    Pattern(One cultivation & Harvesting for each year). The

    normal period of cultivation and harvesting for paddy is six

    months. In the above situation the branch is of the opinion

    that the two crop seasons refers to two years (not one year

    as assumed by us) and the accounts become NPA if the

    principal & interest remains overdue for two & half years. Is

    the contention put forth by the bank is in accordance with

    RBI guidelines? If it is correct, What is the sort of evidence I

    should obtain to conform that the above crop comes under

    one cropping pattern? Please elucidate.

    2) Agricultural Tractor advances are given under Annual

    Installments and for lands under paddy cultivation (Single

    Cropping). In the above situation the branch is of the

    opinion that the two crop seasons refers to two years (not

    one year as assumed by us) and the accounts become NPA

    if the principal & interest remains overdue for three years. Is

    the contention putforth by the bank is in accordance with RBIguidelines?

    2 In respect of Agriculture Advances, the bank management

    says that fresh NPAs identified during the audit are covered

    by Waiver scheme announced by the Honourable Finance

    Minister in the budget speech. Kindly advise whether to go

    without classifying them as NPA in the absence of any

    circular from RBI.

    1

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    3 I want to know about NPA classification of discounted export

    bills guaranteed by ECGC. Bill discounted by bank is of 120

    days maturity and generally paid after long overdue period.

    The bank management has not classified them NPA

    because they are covered by guarantee of ECGC, i.e.,

    Central Government. I have gone through the RBI mastercircular but failed to get reply in clear terms. Please guide.

    Sub: Statutory audit of banks 07-08

    Agricultural advances are usually re-scheduled in certain

    districts in the month of March as drought affected area and

    not classified as NPA. Since there is a proposal in the

    budget for debt relief to farmers, the banks cannot re-

    schedule such accounts as the applicants fear that they may

    be out of the relief programme because of such re-

    schedulement. The Branch Managers are in a difficultsituation as they cannot re-schedule such accounts at their

    own risk without obtaining application as the proposed

    scheme may exclude such accounts. Whether all agricultural

    advances not re-scheduled in time are to be classified as

    NPA?

    Please guide me regarding treatment of loan waiver recently

    announced by the government. What will be treatment of

    NPA agricultural loans waived?

    6 As per declaration in budget, Agricultural loans are to be

    waived upto a certain limit. Now on 31st

    March, 2008, banks

    can not waive the same and even can not re-schedule. So

    whether same should be considered as NPA as on 31st

    March 2008 or not. Please clarify

    4

    5

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    7 The branch is granting, besides crop loans, Term loans to

    agriculturists for purchase of Tractors, Housing and Cash

    Credit for Business under Agro Mortgage Scheme. The

    interest is charged at monthly rests but the instalment

    collected is at the end of the year. The guidelines clearly say

    that the interest not serviced for more than 90 days is to beclassified as NPA. The guidelines are as follows:

    Page 1.132 Para 6.166-167-170-172:

    In line with the international best practices and to ensuregreater transparency, the Reserve bank of India has directed

    the banks to adopt the "90 days overdue" norm for

    identification of NPAs from the year ending March 31, 2004.

    Banks have been charging interest at monthly rests, from

    April 1, 2002. However the banks were advised that the date

    of classification of an advance as NPA would not be

    changed on account of charging interest at monthly rests.

    Banks should, therefore, continue to classify an account as

    NPA only if the interest charged during any quarter is not

    serviced fully within 90 days from the end of the quarter.

    A loan granted for short duration crops will be treated as

    NPA, if the instalment of principal or interest thereon remains

    overdue for two crop season and a loan granted for long

    duration crops will be treated as NPA, if the instalment of

    principal and interest thereon remains overdue for one crop

    season.

    As per guidelines, "long duration" crops would be crops with

    crop season longer than one year crop, which are not "long

    duration" crops would be treated as short duration" crops.

    The crop season for each crop, which means the period upto harvesting of the crops raised, would be as determined by

    the State Level Bankers' Committee in each State.

    Depending upon the duration of crops raised by an

    agriculturist, the above NPA norms would also be made

    applicable to agricultural term loans availed by him.

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    The above norms should be made applicable to all direct

    agricultural advances as listed in the Master Circular on

    Lending to Priority Sectors (RPCD.No.Plan. BC.

    84/04/09.01/2006-2007 dated 30th

    April 2007.) In respect of

    all other agricultural loans, identification of NPAs would be

    done on the same basis as non-agricultural advances,which, at present is the 90 days delinquency norm.

    I am suggesting to classify all the loans (except those

    sanctioned against crops) granted for business or purchase

    of assets and housing etc., as NPAs for which the bank is

    resisting. Kindly advise as to the classification of such loans

    whose interest is not serviced in 90 days.

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    REPLY

    Both your queries are in respect of agricultural advances

    and issue in both the queries is common .i.e. nature of crop

    whether it is long duration or short duration. As I understand

    from your query, in your view the crop in question is short

    duration crop but in view of the Bank, the crop is long

    duration crop. In such situation what is the recourse

    available to you as auditor? I invite your attention to

    para 4.2.12 of Master Circular dated 2nd July 2007 issued

    by Reserve Bank of India. In sub para (i) of this para it is

    very clearly mentioned as under. The

    crop season for each crop, which means the period up to

    harvesting of the crops raised, would be as determined by

    the State Level Bankers' Committee in each State.

    Depending upon the duration of crops raised by anagriculturist, the above NPA norms would also be made

    applicable to agricultural term loans availed of by him."

    In my opinion, if you have any different view on duration of

    crop as stated by the Bank management, then you can

    definitely insist for the State Level Bankers' Committee

    report for determination of crop season for the crop in

    question and accordingly classify the advance as NPA or

    otherwise.

    The agriculture loans scheme is a budget proposal

    submitted by the Hon. Finance Minister in House

    (Parliament). The proposal is yet to be approved and

    become effective. RBI has also not issued any

    communication amending the existing instructions regarding

    NPA(Agricultural Advances). As such, all the agricultural

    advances, including those which are likely to be covered by

    the budget proposal, will have to be classified and provided

    for as per the existing guidelines of RBI.

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    Classification of NPA is based on record of recovery. The

    same is not dependent on availability of security. In the

    above case, the advance is an NPA, if it is overdue for more

    than 90 days after the due date of payment. Availability of

    ECGC cover will only affect the security status for

    provisioning if it is to be classified as doubtful.

    Till today, no circular in this regard has been issued by RBI

    and hence there is no modification in the Master Circular on

    IRAC issued by RBI on 2nd

    July, 2007.

    2. If any internal circular / guideline has been issued by the

    respective bank, the auditor should take cognizance of the

    same.

    3. If no such circular / guideline is issued, the branch

    auditor should make a reference of the same in his statutory

    audit report with a request to the Statutory Auditors to deal

    with it appropriately at the central level.

    Income Recognition and Asset Classification norms in

    respect of advances given by Banks as per Reserve Bank

    of India Master circular dated 2nd July, 2007 are required to

    be applied to agricultural advances also. Therefore an

    agricultural advance will have to be classified as NPA, if by

    virtue of the above referred norms it has become NPA.

    If any advance is not rescheduled as per the scheme, the

    same shall be required to be classified as NPA, if it fulfills all

    other conditions of a NPA under IRAC norms prescribed by

    RBI.

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    I agree with your view regarding the term loans to the

    agriculturists for purchsase of equipments and other

    mortgage loans, etc.

    However, if these loans are granted to agriculturists and if

    the repayment of these loans are dependant upon the

    cropping pattern of the area and accordingly the repayment

    schedule has been prepared as per loan document and if

    the terms of repayment have been finalized accordingly,

    then the accounts shall continue to remain standard , if the

    repayment is as per scheduled terms.

    It shall depend upon the contract terms , which woulddepend upon the cropping pattern and cash flows of the

    agriculturists.

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    ISSUE

    1 To conduct stock audit the borrower should enjoy limit of

    Rs. 5 cores. This limit is only OD limit or consolidated limit

    enjoyed by the borrower in a bank?

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    REPLY

    The limit will mean the OD limit. The limit referred by RBI

    are all working capital limits.

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    LFAR

    Q5. LFAR certification requires lot of time to be spent for

    verifying the correctness of the controls and procedures.

    However due to deadline of completing 3 branch audits by

    7th of April, how to tackle the situation.

    1. Should we need to check and verify all the account

    opening forms for accounts opened during the year under

    audit to comment on KYC norms, more particularly when

    the branch is not covered by concurrent audit and no

    internal inspection took place at the branch during the

    period under audit?

    2. The branch (not a branch dealing in large advances /

    assets recovery branch) has one account with exposure

    (FB & NFB together) in excess of 300 lacs, should we

    obtain the Annexure to the LFAR prepared by the branch

    in such a case?

    DOCUMENTATION

    When documents, like, D.P Note, Agreement for

    Hypothecation of Stock/Book debt and Acknowledgement

    of Debt, etc., are time barred, i.e,, they are more than 3

    years old. Whether it is compulsory to get each and every

    such documents to be renewed or there is any other

    single document that can increase the validity of all such

    documents.

    SENSITIVE STATIONERY

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    Register showing receipt, issue and balance stock of

    stationery comprising of security items (Term Deposit

    Receipts, Drafts, Pay Orders, cheque books, Travelers

    Cheques, Gift Cheques, etc.) is not maintained. Only

    partial details about issue of such stock are available.

    Shall I qualify main audit report or LFAR only?

    FRAUD

    During the course of a Branch audit, we noticed the

    occurrence of a fraud during the year.

    This was identified by the branch and reported to the

    immediate higher authorities.

    However, a criminal case is filed against the bank officials

    also along with other accused persons by the aggrieved

    person and an FIR is filed for the same.

    We need to report it under LFAR.

    We need clarification whether the same should be

    reported by us to RBI, since our appointment order

    requires us to report any occurrence of frauds below Rs.

    100.00 Lakhs to RBI, Regional Office. Whether report to

    RBI is only for a fraud discovered under audit or all frauds

    already identified and reported to Vigilance department of

    the respective bank?

    We are not informed about status of information submitted

    to RBI by the bank.

    Please clarify whether reporting under LFAR will suffice or

    we should also report it to RBI also?

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    Please ensure that you have adequate number of

    assistants to conduct the audit. Having accepted the audit,

    it is the duty of the auditor to ensure that the audit is

    completed within the agreed time period. But lack of time isnot a justification for dilution in the quality of the audit. Full

    compliance needs to be made with all the applicable SAs.

    Read the Guidance Note on Bank Audit.

    There is no specific circular/ instructions either from RBI or

    the Head Office of the Banks requiring 100% checking of

    account opening forms by the statutory auditor. The

    concurrent audit scope definitely requires checking of 100%

    accounts opened during the year. The statutory auditor can

    do it on test check basis, however, the sample size is

    dependent on number of factors, such as, volume of new

    accounts opened, internal control in the branch etc.

    Accordingly, the sample size can be increased. Further, as

    the Branch is not under concurrent audit and internal

    inspection, the size of the branch might be small, therefore,

    the auditor can take decision of sample size.

    Annexure to the LFAR viz., questionnaire applicable to

    specialised branches is required in respect of branch

    dealing in very large advances, such as, corporate banking

    branches and Industrial finance branches with advances in

    excess of Rs.100 crore or Asset Recovery branch.

    Every individual docs. Need to be renewed.

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    From the query, it appears that this is a routine shortcoming

    in the branch. There is no indication in the query that the

    auditor feels that there is some sort of shortage of stock,

    which could lead to some fraud. In that case, it would

    only be reporting in the LFAR. However, if there

    appears to be a theft in the security items, indicating anintention to defraud the bank, then this would need to be

    highlighted in the main report.

    Any fraud detected during the audit should be brought in to

    the notice of the CMD, CSA and RBI. Earlier frauds

    reported must have been already brought in to the notice of

    competent authorities.

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    Whether beside writing No / Yes in Ghosh / Jilani

    Committee reports, we can attach our detailed

    observed to these reports?

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    Yes, you can certainly attach your detailed

    observation and in the questionnaire at the end you

    could mention subject to your observation in a

    separate annexure or read with separate annexure.

    it is advisable to prepare a detailed report

    giving negative assurance on the lines of

    limited review and also stating scope and

    limitation. Just saying yes or no is not in the

    interest of the auditor.

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    OUR DOUBT REGARDING CLASIFYING THE NPA.

    ACCOUNT DETAILS :

    NAME : XYZ LTD.

    LIMITS : OCC : 200 LACS PRESENT O/S.280 LACS LC : 100 LACS

    O/S. NIL

    EXCESS OVER LIMIT SINCE OCT.,2008 LCs devolved and paid by the

    bank by debiting OCC during sept07 to mar08. Interest is also not serviced

    during last 6 months.

    Security : II charge over factory building and machinery along with XYZ

    bank (I charge) fire accident occurred in the company premises on

    28/03/2007 and part of the unit damaged and effect the major part of the

    production.

    Bank referred this account to CDR for restructuring along with bank. CDR

    Committee accepted this account for consideration but not yet given the

    restructuring details.

    Branch not classified this as NPA. There version is when the case is

    pending with CDR, status required to be maintained i.e. required to be

    continued as standard.

    Please give your opinion regarding this account.

    Please explain about the treatment to be given to the following type of

    account :-

    "A C/C account of trading firm where monthly credits in the account are just

    equivalent to the monthly interest debited to it." The balance is within the

    DP.

    1

    2

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    Facts of the case:

    Term Loan Sanctioned in April 2005- 8.90 lacs; Moratorium- 6 months;

    Tenure - 84 months; EMI - Rs. 16646/- Rate of Interest BPLR +12.5%

    (presently 14%p.a.)

    Borrower has requested the bank for re-schedulement of EMI (in November

    2005) to Gradually (increasing) monthly installments such that initially the

    EMIs would match the monthly interest and gradually increase over the third

    year to seventh year, such that the term loan could be repaid in full. Bank

    has accepted the request and accordingly allowed re-schedulement.

    Borrower has till date repaid the committed EMIs as per re-schedulement.

    During April 2007, bank migrated from old software to core banking. While

    doing so, the re-schedulement sanctioned earlier has not migrated

    effectively. EMIs of 2nd

    year alone are reflected in the system during the

    year under audit.

    Meanwhile, the concerned officers, re-calculated the repayment profile upto

    2012 (covering 84 months) and have reported that the rescheduled EMIs

    would not be adequate to square off the term loan in 2012. Hence,

    computed the desired outstanding balance as at 31-03-2008 (from the

    repayment profile) and compared the same with the balance shown by the

    system and reported in October 2007 that the term loan would slip in to NPA

    category if the difference is not made good by the borrower.

    3

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    Meanwhile, the borrower has deposited aggregate amount during the 12

    months which is more than the re-scheduled EMIs and also cover the

    interest debited during the year. The bank has not given any written

    intimation to the borrower about the shortfall as at 31st

    March 2008. The

    borrower has deposited the amounts rather not as per schedule but has

    taken care to deposit more than the given EMIs. The bank has marked theaccount as NPA in December 2007. Now, the borrower has been called for

    and has been asked to deposit an amount equal to the difference between

    the system balance and the desired balance. The borrower has argued that

    if he has paid an amount equal to 12 EMIs (rather more than 12 EMIs taken

    together) during the year, how could be his account be classified as NPA?

    Query: Kindly advice as to how do we look at the account. Whether it would

    fall into NPA? And whether the action taken by the bank is justified? Is it not

    the banks' responsibility to communicate with the borrower that the

    rescheduled EMIs are short to address the repayment of the term loan over

    the sanctioned tenure?

    4 My query is about classification of NPA. A Term loan account is sanctioned

    with the stipulation that interest and principal to be serviced annually.

    According to a RBI Circular, I heard, banks should provide interest only on

    monthly basis. Accordingly, if the interest is paid once in a year, does the

    account become NPA?

    5 The bank has got a Loan Scheme by the name of Traders Easy loans.

    Under this category of loan, Cash Credit limit is allowed to the party against

    the Property mortgaged. No condition of arriving at the periodic drawing

    power through monthly stock and book debt statement is being prescribed.

    Even the parties with negative working capital keep enjoying working capital

    facility as the same is being allowed against the property mortgaged and not

    against the Working Capital Requirement.

    6 The Bank is having another loan scheme of Channel Financing, where limit

    is sanctioned to a dealer of a reputed manufacturer at his recommendation(

    without any guarantee or comfort). The limit is allowed by making direct

    payment to the manufacturer to the extent of the limit without having any

    condition of maintaining the net working capital justifying such limit. Even

    the dealer having negative working capital is enjoying working capital limit.

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    7 Facts of the case: Particulars of advance made by a bank branch. 1.

    Nature of Industry Sugar Manufacture 2.

    Nature of Advance : Working Capital Term Loan

    3. Nature of Security:

    Primary security: Book Debts

    Collateral Security: Immovable Properties

    4. Account Performance : Current. Well serviced (although it is apparent

    that the party is doing kite-flying viz., borrowing from one financier to fulfil

    current loan commitments.) 5.

    Book debt statements not submitted for a long time more than a year.

    6. Collateral adequately covers the loan exposure.

    Query: Does non-submission of book debt statement merit the account to

    be classified as NPA.

    If it was a CC/OD account it is clear that non-submission of stock / book-

    debt statements for more than 3 months would necessitate the account to

    be treated as out of order. Would like to know the position if it was an

    exposure in the nature of a WORKING CAPITAL DEMAND LOAN

    since DP is not drawn based on latest stock/book-debt statements in

    this case.

    8 1. In a trading account, deficits were observed in the OCC account for aperiod of two months and subsequently the bank sanctioned Working

    capital demand loan (WCDL) and the deficit portion was culled out from

    OCC and absorbed in the WCDL. After that the OCC accounted was

    operated within the drawing power availability and the repayment in the

    WCDL was regular. My question is whether the bank can sanction one

    credit facility to regularise the irregularity and to avoid the account becoming

    irregular. (Sanctioning of a loan is a management decision, but the thing is

    to regularise the account the new credit facility can be utilised) Can I

    classify the account as NPA in view of making the account evergreen.

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    9 2. After the implementation of the nursing programme, the unit responded

    well and the account was upgraded as performing after watching one year

    satisfactory performance of the unit. As a part of the nursing programme,

    interest sacrifice made by the bank till the date of implementation of the

    nursing programme, was kept in the mirror account and instructions were

    given to recover the mirror balance every month at a specified quantumand the recovery was credited to P & L account every month. Now my

    question is, as the account has become performing, whether entire interest

    portion in the mirror account can be recognised by transfer to P & L A/C

    credit and debiting the Loan A/C in the year of upgradation of the account

    as performing.

    1. If one account is become NPA during F.Y.07-08 and it has unrecovered

    interest of Rs.10000/- in FY 07-08 and beside this, there is unrecovered

    interest of Rs.3000/- in FY 06-07. Then reversal of interest during the

    year would of Rs.10000/- or 13000/-

    2. If one the account should have been NPA in the FY 05-06 but it was not

    done by the management as well as auditors of FY 05-06 and 06-07. Then

    in FY 07-08 how statutory auditor should dealt with such account.

    The loan was sanctioned in 1998 for doing medicine in Russia and as per

    the original scheme the loan repayment was to commence from 2004 June

    onwards. since the Russia degree was not recognised, the student was to

    take one more course in India and the repayment did not commence in

    2004. The branch deferred the recovery of loan to 2008, I. e., till thecompletion of the new course.

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    Now the issue is, as per the original scheme, the loan is to be repaid within

    one year from the end of the first course or within 6 months from the date of

    employment and in this case the loan was for the first course and any other

    degree subsequent to the first degree amounts to taking up other degree

    and in my opinion the loan repayment is to commence as per the earlierschedule. But the bank differs with our views and did not has not classified

    the account as NPA on the ground that the course is not completed.

    It is very encouraging for the members that the Institute has started the

    facility for online reply to the queries relating to bank audits. There are some

    confusions which I request be cleared. Please clarify the role and the

    course of action in the following situations :-

    1. A CC account in which Rs 31000 is the interest debited for Q4 2007-08.

    There is only one solitary credit entry of Rs 26000 cash deposit on

    31.3.2008. The branch manager is adamant for not classifying it as NPA

    since only half months interest is in arrears. Please clarify.

    2. It has been mentioned in the Guidance Note to be careful about those

    loans in which there is only a single credit entry about the year end.

    Suppose there is a credit in the CC account around the end of the year by a

    contra debit in another CC account with the assertion that the latter is a

    relative of the former and has verbally consented for the transfer of money

    in the formers account. What is the remedy if after the completion of the

    audit the amount is reversed back.

    3. What is the NPA status of a CC account in which there is no credit during

    the last quarter of 2008 and on 1.4.2008 there is a cash deposit of double

    the amount of interest debited during the fourth quarter . The Manager is

    adamant to transfer it to NPA.

    4. A borrower is enjoying various credit facilities in the branch. One of his

    accounts is CC against mortgage of building & is a small account. Ignorantly

    there is no credit in the account for the last 180 days. The managers

    assertion is that if you classify this account as NPA, all other accounts many

    of which form a substantial part of the banks advances will turn NPA. Please

    clarify.

    5. A CC account where the balance is in excess of the sanctioned limit

    during the entire year except 31st

    March, 2008 when it is brought within

    sanctioned limit

    An housing advance was classified as NPA on 31.03.07, details of the

    same are as follows:

    Date of sanction: 10.05.2005

    Moratorium Period: 6 months

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    First installment date/Due Date: 10.12.2005

    Amount Sanctioned: Rs. 6.50 Lacs

    O/s as on 31.03.2007: 6.47 Lacs

    During year 2007-08 (till 23.02.08) there were credits of Rs. 49,000/-(which

    as per branch/system) were enough to convert the account from NPA to

    Performing Asset. After the same the system charged the due interest from01.04.2007 till February 2008, which debited the account by Rs. 61900/-(out

    of which 51,273 pertain to period 1.4.07 to 31.12.07 which was levied on

    10.03.08). Against interest levied till 31.12.2007 only Rs. 6,000/- have been

    received on 27.03.2008.Now as on 31.03.2008 the outstanding amount is

    Rs. 6.55 Lacs.

    Now my questions are:-

    1. Was the system/branch correct in converting the account from NPA to

    Performing Asset?

    2. What should be classification of advance as on date?

    The borrower is running Poultry business whose loan was sanctioned in

    2005 enjoying Term loan and CC limits of Rs 1 Crore. The repayments are

    not satisfactory. The Branch has the practice of re-scheduling the loan when

    it is on the verge of becoming an NPA. Two re-schedulements have already

    taken place and a third has been done on 27.03.08 wherein the limit has

    been reduced to Rs 20 lacs and the balance has been asked to be repaid

    out of sale proceeds of few securities released for sale. The time permitted

    for sale is June 2008.

    The Branch argues that in view of the re-schdulement the account is

    standard. The Master Circular on classification released by RBI is silent on

    re-schedulement of loans other than project loans. Does it mean that the 90

    days norm has to be adopted for the original sanction terms?

    If the argument of the branch is to be accepted then it can be ensured by

    the bank that no account becomes an NPA by merely re-scheduling all

    loans when they are about to become NPAs.

    I request you to please clarify how an advance (C/C) should be classified

    when it has become NPA as on 31-3-2008 and again on 05-04-08 (before

    audit completion), the Assets has become performing. Will it be correct to

    classify the asset as Standard in view of the fact that the same has become

    a performing asset within the audit period.

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    As per RBI Master Circular dated 2/7/2007, even if an account is approved for

    restructuring, classification as Standard or NPA will be done as per the status of the

    account when it goes/is approved for restructuring. In this case even if account is

    approved for CDR, if at the time of submission of the proposal for restructuring the

    account was Sub Standard, then it has to be classified as NPA.

    You need to examine in detail sequence of event on these lines and also the status of

    account when it was sent for restructuring.

    If at the time of submission of proposal, if an account was NPA then it has to be

    classified as NPA. Thus if at the time of submission of proposal if an account was out

    of order for more than 90 days then it has to be classified as NPA.

    As per the RBI Master Circular, there are certain timelines specified for the whole

    CDR process, it is not clear from the query as to at which stage the whole process is

    and moreover the statement that CDR Committee accepted this account for

    consideration but not yet given the restructuring detailsdoes not convey the stage or

    progress.

    Please refer paragraph (iv) on Stand Still clauses on page 18 which states that,

    during pendency of the case with the CDR system, the usual asset classification

    norms would continue to apply. The process of re-classification of an asset should not

    stop merely because the case is referred to the CDR cell.

    Please refer to Master Circular - Prudential Norms on Income Recognition, Asset

    Classification and Provisioning pertaining to Advances dated July 2, 2007 issued byRBI (can be viewed on RBI site - www.rbi.org.in)

    1. Please refer to para 2.2 for the definition of 'out of order'. Under this definition, the

    account is technically not 'out of order'

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    2. Please refer to para 4.2.5. The account should now be examined in light of this

    para, which says that 'a account with few credits only needs to be handled with care' .

    Since this is a trading concern and if this is the only account being operated by the

    borrower, then absence of debit and credit entries for purchase and sale of goods

    prima facie denotes that the business is not operative. The auditor should examine

    other available documentary evidence like stock statements, inspection reports, stockaudit reports, etc. as well as enquiry with the bank officials as to the reason why there

    is no operation in the account, to come to the conclusion that the account has

    'inherent weakness', on the basis of which the account can be classified as NPA.

    3. Knowing the reason for non-operation is very necessary since the borrower may be

    having two accounts - one for stock and other for book debts or may be having an

    actual operating account in some other branch of the same bank or at times may be

    routing his transactions through the current account of the firm and not the cash

    credit account. In all such cases, the non-operating account cannot be considered as

    NPA.

    At one place it is stated that the bank has accepted the request and has allowed re-

    schedulement, whereas at other place it is stated that the re-schedule EMI would not

    be sufficient to square off the loan by 2012.

    There seems to be some technical error on the part of the bank. Assuming that the re

    schedulement has been accepted in writing by the bank, the borrower cannot be

    penalized for shortfall, if any, detected later on. The shortfall can be explained to the

    borrower and can be recovered separately. In my opinion, pending that, if the

    borrower has paid EMI as per the rescheduled terms till December 2007, the account

    cannot be treated as NPA as on 31 March 2008.

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    The definition of due date is defined in paragraph 2.4 of the RBI Master Circular. It

    defines due date as date fixed by the bank. In the given case, it is appears that the

    bank has fixed annual date for servicing interest and accordingly it has to be

    considered for NPA classification.

    Many banks especially private/foreign have the concept of overdraft against property

    which is also financed as a working capital product without obtaining Stock/Book debt

    statements. The bank is in order of doing the same. The account can be classified as

    NPA only based on record of recovery. Stock statement non receipt or negative

    working capital is a non issue in this case.

    NPA Classification is based on record of recovery. In this case, even though it is a

    faulty appraisal, the same can be brought out in the LFAR. However classification as

    NPA can only be done only if there are overdues for more than 90 days.

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    From the facts given, it appears that there are apparent credit weaknesses such as

    absence of primary security, dependence on collateral security for the purpose of

    recovery in case of default in servicing the loan as also obvious kite flying operations

    such as borrowing from other financiers for the purpose of servicing the present loan.

    All the factors indicate that the borrower is in difficulties and may not be able to

    service the loan for long. In such a scenario, you may take a call on the situation andask the branch management to classify the advance as NPA.

    At the same time, if the quantum of advance is substantial, it would be better to

    confirm your decision by making a visit to the borrowers' factory to verify the present

    position of the production, sales, etc. as also whether his factory is really in operation.

    You may also verify whether he is operating any account with some other bank and

    diverting his business to that bank. Since mere non-submission of book debt

    statement may not be enough to classify the account as NPA particularly when he is

    otherwise servicing the loan properly, it need to corroborate the decision you arrive at

    by evaluating the risk to the advance from other evidence.

    My replies to your queries are as under: 1) In the instant case account was irregularand WCDL was given before the account really became NPA. Your observation is

    correct that the account is regularised by sanction of WDCL. In your case after

    sanction of WCDL not only that the OCC is account is within the limit but also that the

    WDCL account is also serviced. In my opinion it appears to be a case of genuine

    need of the borrower and therefore in my opinion the account can be classified as

    Standard. However you need to satisfy

    yourself by verifying the appraisal documents and satisfy yourself about the

    genuineness of the additional loan.

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    In this case even the account is doing well after nursing, in my opinion, it would be

    prudent not to recognise the entire income in mirror account, but account the same as

    income as and when realised.

    Reversal of interest during the year would be Rs.13,000/- As

    per paragraph 3.2.2 on page 5 of the RBI Master circular the words used are fee,

    commission and other similar incomeand it does not specifically say interestor

    discount for the purpose of reversal for the preceding previous year. Logically it

    should also include interest and discount. In any case the matter should be referred to

    the HO and Central Auditors for necessary clarification as the treatment could differ

    from bank to bank.

    As Statutory Auditor ,you have to examine the account independently for the

    F.Y.2007-08. If in your view account is NPA ,it has to be classified as NPA.Moreover

    you have to reverse unrealised interest for the year 2007-08 as well as for the

    previous year depending on the classification. If is was

    due to error or omission in the earlier year it must be corrected retrospectively this

    year but it was a conscious decision of the branch and the branch auditors and there

    is enough documentation to prove that, it may not be treated as error or omission.

    It is not clear from your query, whether the borrower has completed first degree in

    Russia or not; however from language , we presume that he has completed the same

    & loan is utilised for said course.

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    In such circumstances, the first installment is due on original date & determination of

    NPA date starts from that date only depending on repayment. In our opinion, course

    is recognised or not is irrelevant & pursuing another course is also irrelevant. Hence

    you may determine NPA accordingly & if bank disagrees, you have a option of MOC.

    1 In case the interest for 90 days is not recovered by the credits in the account, the

    account becomes NPA. In the present case the partial interest is not recovered

    therefore it is not NPA

    2 RBI suggests to scrutinize the solitary entry at the year end to find out the

    genuinely of the transaction. Thus the auditor has to scrutinize the source of the

    credit entry and take appropriate view.

    3.Technically the position as on 31stMarch should be considered.

    4 The IRAC Norms are objective norms and there is very little scope for the

    sentiments.

    5. Technically the position as on 31stMarch should be considered.

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    An account in the nature of term loan once classified as NPA will be a standard asset

    only if all arrears are cleared. In this case, it appears that arrears are not cleared

    since interest from 1.4.2007 to Feb 2008 is only charged afterwards. Thus branch isnot correct in classifying the account as standard in Feb. 2008 and account is an NPA

    on 31.3.2008 with date of NPA as 31.3.2007. Account status will be doubtful as on

    31.3.2008.

    Apparently the loan appears to be a case of evergreening, i.e., frequent re-

    schedulement. RBI, in Master Circular has clarified that frequent re-schedulement is

    not permissible, You could argue with the bank management on these lines and

    classify the account as NPA. One thing is not quite clear from your query as to how

    tha repayable amount is only Rs.20 lacs instead of Rs. 1 cr which was the original

    loan amount.

    The position of non performing asset is as on 31st

    March. Hence technically the

    position as on that date is valid. However on practical side some people take a view

    on the basis of the subsequent recovery. The auditor should take a overall view of the

    operations in the account to determine whether the concession can be given.

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    Request you to please clarify on the following :

    Previous year MOCs

    The previous auditor has classified certain standard assets

    as sub- standard and has suggested provisions & interest

    reversal. However the branch has not made those changesin their records as they feel they are still standard assets.

    While drafting MOCs for current year, I am going to show

    these as Sub-standard. My queries in relation to above are

    as follows:

    Q1. Whether the prudential norms are to be strictly

    adhered to in framing our MOCs. For example, in term loans

    which were classified by previous auditor as Sub-standard

    and not re-classified by branch, there have been some

    substantial collections during the current year

    however interest and or principal are still overdue for more

    than 90 days. Branch argument is that the account is still

    operating as substantial amounts have been collected and

    should not be classified as NPA. In relation to this, whether

    we have to go strictly by the prudential norms (90 days

    concept) or we can be little liberal to accept their argument.

    Q2. If I show these accounts in MOCs and classify as Sub-

    standard, whether apart from current year interest reversal,

    should I also insist on interest reversal for previous year

    interest suggested in previous year MOCs the accounts of

    which have already been signed.

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    Q3. Whether security can be a criteria for not showing an

    advance as NPA say in case of housing loans backed by

    security of house property, if the defaults fall in NPA

    category should I show it as NPA or not show because it is

    backed by security of house property whose current market

    value can be more than the outstanding amount.

    Q4. Once MOC is created last year and for the same

    accounts if MOC is created in current year as the same has

    not been re-classified by branch, will it not lead to double

    provision at HO level for the same account in two different

    years.

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    The Prudential Norms are to be strictly adhered to.

    The date of the NPA will not change. After 12 months

    from the date of the NPA, the account will have to be

    classified as Doubtful. The interest credited to the

    account but not realized has to be reversed.

    As mentioned above, if the account is NPA for more

    than 12 months, it should be classified as Doubtful.

    The date of the NPA will be the original date as

    ascertained by the previous auditor, assuming that

    the classification carried out by the previous auditor is

    correct as per the RBI Circular.

    Once a credit facility is classified as NPA, the interest

    accrued and credited to the income account in the

    corresponding previous year which has not been

    realized should be reversed or provided for.

    Accordingly the unrealized interest of 2005-06 and

    2006-07 will have to be reversed or provided for in

    2007-08. This will now be classified as prior period

    interest and accordingly reflected in the financial

    statements or shown so by way of MOC.

    Attention is also invited to para 11 of SA 710.

    Reference be made to the Appendix II to this SA for

    the method of reporting, if you find the same to be

    applicable.

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    The security is not a criterion while classifying an

    advance as a NPA.

    As a branch auditor ensure that suitable disclosures

    are made in the audit report. The Central Statutory

    Auditor and the Head Office will ensure regarding the

    double provision.

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    As per section 145 of Income Tax Act that hybrid

    accounting method is not acceptable but I found that

    many bank have following hybrid accounting system.

    Example :

    1) All revenues are accounted for on accrual basis

    except the following items, which are accounted for

    on cash basis :-

    - Income from merchant banking operations,

    - overdue locker rent,

    - interest for overdue period on bills purchased

    2) All cost are accounted for on accrual basis except

    the following items:

    - interest payable on overdue deposits is recognised

    at the time of renewal / payment thereof.

    Should I qualify my report, is it material deviation?

    1

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    The bank audit is guided by Banking Regulation Act

    and Reserve Bank of India Act. There is no question

    of qualifying your report on branch audit as the Bank

    is free to have their policy subject to consistency and

    disclosure as per AS 1.

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    ISSUE

    1 I would like to know the meaning of, 'Check

    whether negative lien is created in case

    immovable assets are not registered with co-

    operative societies.'

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    REPLY

    "Letter / Undertaking for Negative Lien" is an undertaking given by

    the borrower to the bank stating that at present he has not created

    any lien / charge on the concerned assets and that in future, he will

    not create any lien / charge on these assets without the permission

    of the bank.

    This Undertaking is on a stamp paper, but not registered anywhere.

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    1 A form 3CD is provided by bank to me for branch statutory

    audit wherein Annexures including annexure for FBT is not

    provided. Shall a branch auditor has to certify the annexures

    forming part of Tax Audit Report?

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    In case the Bank has not provided for the Annexure

    II, Value of Fringe Benefits in terms of Section

    115WC read with section 115WB, the auditor need

    not on his own furnish it. However it will be advisable

    that in Form No 3CA in Para no 2 and 3, suitable

    disclosure is made that the said Annexure II is not

    being filed.

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    1 Please give us the procedure to convert the data of test

    format (note pad) to excel. Branch has given the loan

    particulars in test format. We need to convert it into excel

    to analyse the data.

    2 What is Core Banking System & how it working?

    3 How I have to operate the same system?

    4 Which report I have to ask from bank in Core Banking

    System?

    5 How I can generate the various report from CBS? Thereis no such information give in our institute reference book

    also.

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    6 I have been alloted a branch which has converted into a

    CBS branch in the 3rd week of March 08. The migration

    audit has not been carried out for this branch.

    I would like to know what kind of qualification I should

    make in my audit report.

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    This is a matter of Information Technology Possibly, the

    system administrator will be of some help to you. It

    is advisable to take permission of the branch

    management to covert the data in such fashion.

    In core Banking, there is a centralised server. All the

    Branches are connected to this node. Effectively, the

    Banking modules are from a single server for all

    branches. Data also is stored in one place. As auditor you

    have the advantage that critical functions of back-up and

    even installation of latest rates of interest are from a

    central place. However, many issues like concession and

    'adjustment of rates' are at branch level. You will finddetails of this in the current and previous year's issue of

    background material of the WIRC. Other Regions may

    have this but I am not aware.

    The Bank will give you a user ID and password. If not,

    insist on it. This gives you access to reports and 'view'

    screens only and no transactions can be passed. As

    auditor you need this and only system tolerance in terns

    of software audit is not permitted to you. Thus you can

    take our reports you want to compare with the schedules

    needed to be signed by you.

    This is your perogative. From the trial balance to Balance

    sheet and even installments in arrears are the normally

    asked reports by auditors. Depth is your right to exercise.

    Go to the reports menu and select the report and pressprint or screen display. Each Bank and software has

    different methods of negotiation in the software.

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    There is no such information give in our Institute

    reference book also. What you are seeking is 'hands on'

    experience for which there is no book. The institute's

    book has sufficient details built if you are seeking audit

    checklist, etc., you need to look at private publications.

    U may add ".....subject to any adjustment arising out of

    reconciliation of figures after migration to CBS..." in your

    audit report. However in any case, the central statutory

    auditors will take care of this.